Opening Up America Again - CMS unveils Flexibilities for Resuming Non-emergent Care

Following the outbreak of the COVID-19 pandemic in the U.S. a month ago, the Centers for Medicare & Medicaid Services (CMS) issued an array of temporary regulatory waivers and new rules to provide the nation's healthcare system with maximum flexibility to deal with this public health emergency. Our medical billing company reported on these developments, including updated guidelines for reporting telemedicine services. 

On March 18, the Centers for Medicare & Medicaid Services (CMS) announced measures to augment services for patients with COVID-19 by "limiting non-essential care and expanding surge capacity into ambulatory surgical centres and other areas". The goal was to preserve resources such as personal protective equipment, beds, and ventilators as well as to free up healthcare workforce to care for patients exposed to the virus. The limits on non-essential care put a hold on elective surgeries and non-essential medical, surgical, and dental procedures. 

Recommendations for Restarting Non-Emergent Procedures
With the federal government's call for Opening Up America Again, CMS announced plans for restarting non-emergent care. In a statement issued on April 19, CMS noted that "at this time many areas have a low, or relatively low and stable incidence of COVID-19, and that it is important to be flexible and allow facilities to provide care for patients needing non-emergent, non-COVID-19 healthcare". CMS plans to restart certain procedural care (surgeries and procedures), chronic disease care, and, finally, preventive care, all of which had been postponed due to COVID-19. 

CMS recommends resuming in-person care of non-COVID-19 patients in regions with low incidence of COVID-19 disease. With the surge in COVID-19 cases, CMS updated policies for telehealth to create a mechanism for patients to stay at home and communicate with physicians on the status of their health, while protecting healthcare workers and the community at large. While encouraging maximum use of telehealth modalities, CMS now recommends that healthcare systems and facilities offer non-COVID-19 care as clinically appropriate and within a state, locality, or facility "that has the resources to provide such care and the ability to quickly respond to a surge in COVID-19 cases, if necessary". These decisions, notes CMS, should "be consistent with public health information and in collaboration with state public health authorities".

The recommendations also outline the general considerations for providing clinically necessary care for patients with non COVID-19 needs or complex chronic disease management requirements, personal protective equipment (PPE), workforce availability, facility considerations, sanitation protocols, supplies and testing capacity. 

General Considerations:

Personal Protective Equipment

Workforce Availability

Facility Considerations and Testing

Sanitation and Supplies

Moving Forward
CMS' plans to reopen non-emergent care will allow many procedures labeled "non-essential" or "elective" to take place. However, a Medpage article published on May 4 observes that many of these procedures that were put on hold due to the pandemic are actually critical for the health and well-being of many patients. Examples of conditions for which delayed treatment can cause severe complications include uterine fibroids with heavy bleeding and pain, severe foot pain that develops complications, and open wounds due to peripheral arterial disease. The report notes that procedures for these conditions may seem elective, but they are truly vital. 

The way forward, according to the article is to improve emergency preparedness in order to maintain the vital healthcare treatments that take place outside of hospitals. 

This can be done by:

As facilities to provide elective surgeries, non-essential medical, surgical, and dental procedures are reopened, the support of an experienced medical billing service provider would be invaluable to prepare and submit claims for appropriate reimbursement. 

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