COVID-19 and Practice Management and Billing

1. My group and I have been hit hard financially. Where can I find information on economic relief, loans and other programs?

• With the passage of the Fiscal Responsibility Act of 2023 and related rescission of COVID-19 program funds, no further payments will be made to providers under the Provider Relief Fund or the American Rescue Plan Rural Distribution, including no reconsideration payments.
• Our advocacy division continues to seek economic relief via legislative and regulatory avenues for anesthesiologists and their groups.  

2. Where can I learn more about Telehealth to determine if that may be a good option for my patients and my practice?

• Despite the end of the public health emergency, the Consolidated Appropriations Act, 2023 provides for an extension for some of the telehealth flexibilities through December 31, 2024. These include the ability to bill Medicare for telehealth services in any geographic area in the United States, rather than only in rural areas, and that certain telehealth visits can be delivered using audio-only technology (such as a telephone).
• CMS is also exercising enforcement discretion to allow teaching physicians in all teaching settings to be present virtually, through audio/video real-time communications technology, for purposes of billing under the physician fee schedule for services they furnish involving resident physicians through December 31, 2023.  Similarly, the HHS Office of Civil Rights (OCR) is providing a 90-calendar day transition period for providers to come into compliance with the HIPAA Rules with respect to their provision of telehealth through August 9, 2023.
• More detail on the continuation of these waivers and flexibilities is available at CMS’ updated guidance on Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19.

3. Where can I find more about Medicare Provider Enrollment Relief during the COVID emergency?

• CMS has resumed collecting application fees, conducting Criminal Background Checks, and revalidating providers and suppliers in a phased approach.
• Providers with temporary billing privileges established during the COVID-19 pandemic will be separately asked by their MAC to submit a complete CMS-855 enrollment application in order to establish full Medicare billing privileges.  

4. Where do I ask compliance questions about federal relief and the appropriate management and use of federal relief funds?

• The compliance flexibilities provided by the HHS Office of Inspector General (OIG) generally terminated with the end of the public health emergency.

Additional Information

• General
• Anesthesia Machines and Equipment Maintenance
• Clinical Care
• Elective Surgery
• Federal Advocacy
• Hospital and Facility Administration
• Occupational Safety and Wellness
• Personal Protective Equipment
• Patient Testing
• Vaccines

Disclaimer

Viewers of this material should review these FAQs with appropriate medical and legal counsel and make their own determinations as to relevance to their particular practice setting and compliance with state and federal laws and regulations. The ASA has used its best efforts to provide accurate information. However, this material is provided only for informational purposes and does not constitute medical or legal advice. This response also should not be construed as representing ASA policy (unless otherwise stated), making clinical recommendations, dictating payment policy, or substituting for the judgment of a physician and consultation with independent legal counsel.