COVID-19: Enrollment Relief, Open Payments, Beneficiary Notices

The Centers for Medicare and Medicaid Services have released the following updates on March 26:

2019-Novel Coronavirus (COVID-19) Medicare Provider Enrollment Relief Frequently Asked Questions (FAQs)

CMS released Frequently Asked Questions on Medicare Provider Enrollment Relief related to COVID-19 including the toll-free hotlines available to Medicare Administrative Contractors (MACs). CMS has established toll-free hotlines at each MAC to allow physicians and non-physician practitioners to initiate temporary Medicare billing privileges. These hotlines provide expedited enrollment and answer questions related to COVID-19 enrollment requirements. FAQ

Frequently Asked Questions (FAQs) on Enforcing Open Payments Deadlines

CMS released an updated comprehensive list of Frequently Asked Questions (FAQs) about the Open Payments program. Tuesday, March 31, 2020 is the Open Payments Program Year 2019 data submission deadline for applicable manufacturers and group purchasing organizations (GPOs) to submit and attest to data for the June 2020 publication of Program Year 2019 data. The deadline cannot be extended past March 31, 2020, therefore, CMS will exercise enforcement discretion for submissions completed after the statutory deadline due to circumstances beyond the reporting entity’s control related to the pandemic. FAQ

Beneficiary Notice Delivery Guidance in light of COVID-19

If you are treating a patient with suspected or confirmed COVID-19, CMS encourages the provider community to be diligent and safe while issuing the following beneficiary notices to beneficiaries receiving institutional care:

  • Important Message from Medicare (IM)_CMS-10065
  • Detailed Notices of Discharge (DND)_CMS-10066
  • Notice of Medicare Non-Coverage (NOMNC)_CMS-10123
  • Detailed Explanation of Non-Coverage (DENC)_CMS-10124
  • Medicare Outpatient Observation Notice (MOON)_CMS-10611
  • Advance Beneficiary Notice of Non-Coverage (ABN)_CMS-R-131
  • Skilled Nursing Advance Beneficiary Notice of Non-Coverage (SNFABN)_CMS-10055
  • Hospital Issued Notices of Non-Coverage (HINN)

In light of concerns related to COVID-19, current notice delivery instructions provide flexibilities for delivering notices to beneficiaries in isolation. These procedures include:

  • Hard copies of notices may be dropped off with a beneficiary by any hospital worker able to enter a room safely. A contact phone number should be provided for a beneficiary to ask questions about the notice, if the individual delivering the notice is unable to do so. If a hard copy of the notice cannot be dropped off, notices to beneficiaries may also delivered via email, if a beneficiary has access in the isolation room. The notices should be annotated with the circumstances of the delivery, including the person delivering the notice, and when and to where the email was sent.
  • Notice delivery may be made via telephone or secure email to beneficiary representatives who are offsite. The notices should be annotated with the circumstances of the delivery, including the person delivering the notice via telephone, and the time of the call, or when and to where the email was sent.

We encourage the provider community to review all of the specifics of notice delivery, as set forth in Chapter 30 of the Medicare Claims Processing Manual. https://www.cms.gov/media/137111

CMS has taken several recent actions in response to the Coronavirus Disease 2019 (COVID-19), as part of the ongoing White House Task Force efforts.  A summary of recent CMS activities can be found here: https://www.cms.gov/newsroom/press-releases/cms-news-alert-march-26-2020

To keep up with the important work the Task Force is doing in response to COVID-19, visit www.coronavirus.gov. For information specific to CMS, please visit the CMS News Room and Current Emergencies Website.

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