CMS Encourages Reopening of Healthcare Facilities
On June 9, 2020, the Centers for Medicare and Medicaid Services (CMS) released additional guidance on reopening healthcare facilities.
- Centers for Medicare & Medicaid Services (CMS) Recommendations: Re-opening Facilities to Provide Non-emergent Non-COVID-19 Healthcare
- Patient Guide in English
- Patient Guide in Spanish
- CDC information on individuals at higher risk for serious illness from COVID-19
Epilepsy Organizations Develop Guidance on Re-opening Epilepsy Centers in light of COVID-19
NAEC has collaborated with colleagues from the American Clinical Neurophysiology Society, American Epilepsy Society, American Academy of Neurology, and ASET – The Neurodiagnostic Society to provide our members with guidance related to providing inpatient and outpatient epilepsy services during and following the COVID-19 public health emergency.
NAEC Town Halls on COVID-19 and Epilepsy Center Operations
In early May, NAEC hosted Town Hall webinars for members to discuss how COVID-19 has affected their center operations and their plans for reopening their epilepsy centers, if applicable. The links to the Town Hall recordings and slides presented during each session are below.
Adult Centers Town Hall
Pediatric Centers Town Hall
NAEC is working with its sister organizations, including ACNS, AES, the AAN Epilepsy Section and the Epilepsy Foundation, to provide resources to the epilepsy community as it responds to the COVID-19 emergency. NAEC will regularly update this page as additional materials are created and released. Please contact us with any questions.
On March 30, 2020 and April 30, 2020, the Centers for Medicare and Medicaid Services (CMS) issued Interim Final Rules providing significant flexibility in Medicare coverage and payment for hospital and physician services and waivers on other Medicare and Medicaid requirements. Most of these changes were made effective as of March 1, 2020 and will continue through the government declared public health emergency or December 31, 2020. Summaries of the March 30 Rule and April 30 Rule can be found on the NAEC Website.
In addition, NAEC has prepared a one-page fact sheet on Medicare’s allowances for telehealth and telephone only services with a chart showing CPT Codes and national average payments. Many private insurers and state Medicaid plans have instituted similar policies related to telehealth.
Thanks to the ninety-two centers that participated in NAEC’s COVID Survey. The evolving COVID-19 pandemic is causing rapid and unprecedented changes in inpatient and outpatient policies and procedures across the country. NAEC will continue to provide its members useful information during this critical time. The NAEC survey is designed to collect information about the current status of your epilepsy center operations during COVID-19. We hope that the information that we collect will be helpful to Center Directors as you respond to this crisis.
Use the link below to see the survey results, with key points on the landing page and separate links on the left to access specific survey results. Updates will be posted regularly.
Epilepsy-Related COVID-19 Resources
- Epilepsy Foundation page: Concerns About COVID-19 (Coronavirus) and Epilepsy. EF is continually updating its page on COVID-19 and the potential implications for people with epilepsy and their caregivers. The site’s content is reviewed by the Foundation’s Medical Advisors.
- Epilepsy Foundation: COVID-19 and Epilepsy FAQ
- American Clinical Neurophysiology Society COVID-19 Resources. ACNS took the lead on developing documents related to technologist safety and staffing; equipment maintenance and cleaning; managing requests for neurodiagnostic testing and physician staffing.
- American Epilepsy Society pages: COVID-19 resources for clinicians and COVID resources for researchers. AES has pages with helpful resources for clinicians and researchers related to patient management and medication continuity, and patient access to care, as well as links to public health agency pages on the virus. The page for researchers has information about conducting clinical trials for epilepsy research during the pandemic.
- ASET – The Neurodiagnostic Society. ASET published a SARS-CoV-2 (the cause of COVID-19) Resource Sheet to address the additional procedures technologists should be incorporating.
On March 13th, President Trump declared the COVID-19 epidemic a national emergency, which allows numerous policy changes to be possible related to Medicare, Medicaid and CHIP. Since then, federal policymakers have released a number of new guidances and we anticipate that more changes are likely as federal and state governments, as well as Congress, responds to provider challenges in caring for patients in this extremely difficult time. NAEC will continually update this section as new policies are released.
- Expansion of Telehealth Benefits: On March 17, CMS expanded telehealth benefits for Medicare beneficiaries during the COVID-19 outbreak to allow individuals to receive a wider range of healthcare services without having to travel to a healthcare facility. Clinicians can bill immediately for dates of service starting March 6, 2020 for patients affected by COVID-19 other conditions. Telehealth services are paid under the Physician Fee Schedule at the same amount as in-person services. More info about the telehealth policies may be found here: Medicare Telehealth Fact Sheet and Medicare Frequently Asked Questions.
- HHS Waiving HIPAA Penalties for Telehealth: The HHS Office for Civil Rights (OCR) is exercising its enforcement discretion and, effective immediately, will not impose penalties on physicians using telehealth in the event of noncompliance with the regulatory requirements under the Health Insurance Portability and Accountability Act (HIPAA). For more information, click here. Physicians may seek to communicate with patients and provide telehealth services through remote communications technologies including population applications like FaceTime, Facebook Messenger video chat and Google Hangouts for any reason, regardless of whether the telehealth service is related to COVID-19. This includes any non-public facing services that are available to communicate with patients. Physicians should not use Facebook Live, Twitch, TikTok or other public facing communication services. Physicians are encouraged, but not required, to notify patients of the potential security risks of using these services and to seek additional privacy protections by entering into HIPAA business associate agreements (BAA).
- Medicaid Waivers: State Medicaid programs can apply for Section 1135 waivers to temporarily change their policies in response to the crisis. They are allowed to enact policies such as: to suspend prior authorization requirements; extend existing and authorizations for services where beneficiary previously received prior authorization through the end of the public health emergency; and waive requirements that physicians and other health care professionals be licensed in the state in which they are providing services, so long as they have equivalent licensing in another state, among other changes. As of this writing, 35 states have had 1135 waivers approved. This website has more details.
- State Legislation: Separately, a group called GovPredict has created a dashboard to track state legislation related to COVID-19 across multiple topics including general aid, education, workers compensation, telemedicine, emergency measures, among other topics. Click here to see the dashboard.
- Congressional Activity: Congress has also been extremely busy responding to the COVID-19 emergency. It has enacted three laws to provide additional funding for federal and state public health agencies, health care providers, loans for small businesses and nonprofits, and expanded unemployment insurance and cash payments for individuals. The Coronavirus Aid, Relief, and Economic Security Act or The CARES Act enacted on March 27 also includes health policy changes, such as: to allow for 90-day prescription refills under Medicare Part D; ensure no cost-sharing for COVID-19 tests under Medicare Part B; enact significant expansions of telehealth for new patients and provided by home health, hospice, FQHCs, and rural clinics; and allow for Medicaid to cover COVID testing and vaccines for the uninsured without co-pays. While Congress is now in recess until April 20th, we anticipate that there will be a fourth COVID response bill in the coming weeks.