Tag: Department of Health and Human Services (HHS)

OIG Announces Modernization of Compliance Program Guidance Documents

Written by Meghan Winesett on . Posted in Executive, Government Affairs, Human Resources, Member-Only.

By Brian S. Werfel, Esq.

On April 25, 2023, the HHS Office of the Inspector General (OIG) posted a notice in the Federal Register that it would be updating its publicly available resources, including its compliance program guidance documents.  The OIG’s Compliance Program Guidances (CPGs) were developed as voluntary, non-binding guidance documents that can assist healthcare providers in developing their own internal controls to ensure adherence to federal laws, regulations, and program requirements.

Specifically, the OIG announced that it will no longer publish updated or new CPGs in the Federal Register.  Instead, updates or new CPGs will now be made available on the OIG’s website.  The OIG will also revise the format for CGS.  The new format will consist of: (1) a General CPG (GCPG) that applies to all healthcare providers and (2) industry-specific CPGs (ICPGs) tailored to the fraud and abuse areas specific to that industry.  The OIG indicated that it anticipates issuing the GCPG by the end of calendar year 2023, with ICPGs being issued starting in calendar year 2024.  The OIG further indicated that it anticipates the first two ICPGs will address Medicare Advantage plans and nursing facilities.

Note: the OIG is not updating its 2003 guidance on compliance programs for ambulance suppliers.  The OIG frequently cites this document in enforcement actions it takes against ambulance providers and suppliers.  Thus, this guidance document remains relevant to this day.  For that reason, A.A.A. members are strongly encouraged to review this document to ensure that their existing compliance program incorporates the elements cited by the OIG.

Previous Compliance Program Guidance for Ambulance Suppliers

In March 2003, the OIG issued its “Compliance Program Guidance for Ambulance Suppliers.”  This document sets forth the basic elements that it believes should be included in any effective compliance program, and then discusses various fraud and abuse and compliance risks associated with the provision of ambulance services under the Medicare Program.

The 7 basic elements identified by the OIG are:

  1. The development of compliance policies and procedures
  2. The designation of a compliance officer or compliance committee
  3. The implementation of education and training programs
  4. The use of internal monitoring and reviews
  5. Policies designed to respond appropriately to detected misconduct
  6. Ensuring open lines of communication
  7. The enforcement of disciplinary standards through well-publicized guidelines

The CPG then goes into greater detail on each of these elements, including specific recommendations on how to properly implement each of these elements.  For instance, the OIG suggests that the organization’s compliance office be a high-level individual who reports directly to the organization’s CEO or Board of Directors.

With respect to the specific fraud and abuse risks associated with ambulance, the OIG highlighted the issue of medical necessity.  The OIG also cited level of service issues (i.e., billing ALS vs. BLS), non-emergency transports, and coordination of benefit issues as particular areas of concern.

 

EMS Grant Bill Introduced in House

Written by AAA Staff on . Posted in Government Affairs, Legislative, Member Advisories.

EMS Grant Bill Introduced in House

All EMS Organizations Eligible with Limitations

On Wednesday evening, Representative Andy Kim (D-NJ) along with Representatives Markwayne Mullin (R-OK), Cynthia Axne (D-IA), Mike Carey (R-OH), Marc Veasey (D-TX), Al Larson (D-FL), and Bruce Westerman (R-AR) introduced the Supporting our First Responders Act (H.R. 8994). H.R. 8994 would establish the “EMS Grant Program” with funding at $50 million a year. Grants could be used for the training and retention of paramedics and EMTs, equipment, and facility modifications as well as additional purposes as seen fit by the HHS Secretary.

 

Of significant importance, private sector ambulance service organizations would be eligible for grants under the program. While the total amount available to private EMS would be capped at 2% or $1 million of the funding per year, H.R. 8994 is the first piece of legislation to explicitly state that private for-profit ambulance service organizations would be eligible to apply directly for such grant funding. The AAA worked closely with the sponsors of H.R. 8994 as well as Boundtree and the National Association of Emergency Medical Technicians (NAEMT) on the introduction of the bill.

988 Lifeline Transition – Partner Toolkit and Jobs Web Page

Written by AAA Staff on . Posted in Regulatory, State-Level Advocacy.

HHS PRF | EMS Funding Letter to Secretary Becerra

Written by AAA Staff on . Posted in Executive, Finance, Government Affairs, Regulatory.

Download PDF Letter

March 24, 2022

The Honorable Xavier Becerra
Secretary of Health and Human Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

Dear Secretary Becerra:

Ground ambulance service organizations and fire departments continue to struggle financially from the enduring economic effects of the COVID-19 public health emergency (PHE). Our respective members face sharp increases in the costs of fuel, equipment, medical supplies, and staffing as we deal with a severe shortage of paramedics and emergency medical technicians (EMTs) which has been an issue for years but exacerbated by the pandemic. We implore you to help ensure communities around the country have access to 9-1-1 emergency and non-emergency ground ambulance services through the remainder of the PHE and beyond with an infusion of $350 million from returned and/or unspent money in the Provider Relief Fund (PRF).

We greatly appreciate the funding that ground ambulance service organizations and fire departments have already received from the PRF. The funds have been a lifeline for many of our respective members and their ability to continue to serve their communities. However, as the Phase 4 distribution of funds demonstrated, more funding is needed for ground ambulance services. Our members indicate the funds they received in Phase 4 covered approximately 50% of their lost reimbursement and increased costs from July 1, 2020, to March 31, 2021, whereas previous distributions were closer to 88%. We therefore respectfully request an immediate distribution of $350 million or 10% of the annual Medicare expenditure on ground ambulance services.

We request that the funds be distributed in a similar manner as the Tranche 1 distribution from the PRF. The automatic, across-the-board deposit of funding was especially helpful for small and rural ground ambulance service organizations. These rural organizations provide care in underserved areas and are often daunted even by an abbreviated application process. To ensure equity for all communities, we support universal direct deposit.

Additionally, we encourage HHS to make these payments based on the National Provider Identification (NPI) number of the ground ambulance service organization or fire department rather than Tax ID Number (TIN). In the case of moderate and large cities, many municipal departments may share a TIN while maintaining distinct NPIs. Providing these payments according to TIN may unintentionally comingle funds intended for different departments such as fire departments, public health departments, and local government-run hospitals or clinics.

The American Ambulance Association (AAA), International Association of Fire Chiefs (IAFC), International Association of Fire Fighters (IAFF), National Association of Emergency Medical Technicians (NAEMT), and National Volunteer Fire Council (NVFC) represent the providers of vital emergency and non-emergency ground ambulance services and the paramedics, EMTs and firefighters who deliver the direct medical care and transport for every community across the United States.

Our members take on substantial risk every day to treat, transport, and test potential COVID-19 patients, and play a vital role in providing vaccinations to individuals in their homes. Ground ambulance service organizations and fire departments, however, urgently need the additional

$350 million to help offset the increased costs and lower reimbursement resulting from our vital response to the pandemic.

Thank you in advance for your consideration of this request.

Sincerely,

American Ambulance Association

International Association of Fire Chiefs

International Association of Fire Fighters

National Association of Emergency Medical Technicians

National Volunteer Fire Council

HHS IEA | COVID-19 Update for March 21, 2022

Written by AAA Staff on . Posted in Regulatory.

HHS Office of Intergovernmental and External Affairs COVID-19 Update for
March 21, 2022  
CASE UPDATE
New Cases (based on 7-day rolling average)

  • 79,571,321 U.S. cases
  • 17.3% decrease in new cases (7-day average), as of March 18, 2022

Testing

  • 837,949,940 tests completed (3/21)
  • 2.3% positive test rate as of the week of 3/11 – 3/17/22 (was 2.7 % last week)

Hospitalizations

  • 4,581,254 total COVID hospital admissions (3/18)
  • The 7-day average (3/12 – 3/18) number of new confirmed COVID-19 admissions decreased from 2,642 to 2,010 admissions per day

Deaths

  • 969,114 total U.S. deaths
  • The 7-day average (3/12 – 3/18) number of reported deaths decreased from 1,199 to 973 deaths per day

Vaccines

  • 558,678,770 vaccine doses administered (3/21/22)
  • 76.8% (255 million people) of the population has received 1 or more doses and 65.4% (217.1 million people) of the population have been fully vaccinated
  • 81.6% of people five years and older have received at least 1 dose and 69.5% have been fully vaccinated
VACCINE UPDATES
COVID-19 Vaccines Continue to Protect Against Hospitalization and Death Among Adults: CDC released a statement that COVID-19 vaccination continues to help protect adults against severe illness with COVID-19, including hospitalizations and death, according to two reports released in last week’s MMWR . During Omicron, COVID-19-associated hospitalization rates increased for all adults, regardless of vaccination status, but rates were 12 times higher among adults who were unvaccinated compared to adults who received a booster or additional doses. Hospitalization rates were also highest among non-Hispanic Black adults and nearly 4 times as high among Black adults than White adults during the peak of Omicron. CDC continues to recommend that everyone 5 years and older stay up to date on their COVID-19 vaccines, including a booster dose for those who are eligible. We also must work to ensure everyone has equitable access to vaccines and treatments by focusing efforts on reaching people who have been disproportionately affected, so that they can be protected from the effects of the virus, including severe illness, hospitalization, and death.

FDA to Hold Advisory Committee Meeting on COVID-19 Vaccines to Discuss Future Boosters: The U.S. Food and Drug Administration (FDA) announced a virtual meeting of its Vaccines and Related Biological Products Advisory Committee (VRBPAC) on Wednesday, April 6, to discuss considerations for future COVID-19 vaccine booster doses and the process for selecting specific strains of the SARS-CoV-2 virus for COVID-19 vaccines to address current and emerging variants. Along with the independent experts of the advisory committee, representatives from the U.S. Centers for Disease Control and Prevention and the National Institutes of Health will participate in the meeting.

One-Year Anniversary of Health Center COVID-19 Vaccine Program: Today, the U.S. Department of Health and Human Services (HHS) recognized the one-year anniversary of the Health Resources and Services Administration’s (HRSA)  Health Center COVID-19 Vaccine Program , which received funding from President Biden’s American Rescue Plan and has provided COVID-19 vaccines directly to thousands of HRSA-supported health center sites nationwide. To date, health centers have administered more than 20 million vaccines in underserved communities across the country through the HRSA program and partnerships with states.
TESTING AND TREATMENT
FDA Safety Communication on At-Home COVID-19 Tests: The FDA  issued a safety communication  to alert people of the potential for harm if FDA-authorized at-home COVID-19 tests are not used according to the manufacturer’s test instructions. The FDA is also reminding people to keep the tests out of reach from children and pets. The FDA has received reports of injuries caused by the incorrect use of at-home COVID-19 tests, such as people putting the test chemicals in their eyes, due to the small vials of test solution were mistaken for eye drops. The FDA is also aware of children putting small plastic vials in their mouth and swallowing test solution. This safety communication provides:

  • Recommendations for people using FDA-authorized at-home COVID-19 diagnostic tests
  • Background on the issue and the FDA’s actions
  • Instructions for reporting problems with at-home COVID-19 testing to the FDA

EUA for At-Home Test: The FDA issued an emergency use authorization (EUA) for PHASE Scientific International, Ltd.’s INDICAID COVID-19 Rapid Antigen At-Home Test, an OTC #COVID19 antigen diagnostic on March 16. The FDA is committed to increase the availability of appropriately accurate and reliable at-home COVID19 diagnostic tests, and to facilitate consumer access to these tests.
RESEARCH
COVID-19-Associated Hospitalizations Among Adults During SARS-CoV-2 Delta and Omicron Variant Predominance: CDC released an MMWR on COVID-19-associated hospitalizations among adults during SARS-CoV-2 Delta and Omicron variant predominance by race/ethnicity and vaccination status from fourteen states between July 2021 – January 2022. SARS-CoV-2 infections can result in COVID-19–associated hospitalizations, even among vaccinated persons. In January 2022, unvaccinated adults and those vaccinated with a primary series, but no booster or additional dose, were 12 and three times as likely to be hospitalized, respectively, as were adults who received booster or additional doses. Hospitalization rates among non-Hispanic Black adults increased more than rates in other racial/ethnic groups. All adults should stay up to date with COVID-19 vaccination to reduce their risk for COVID-19–associated hospitalization. Implementing strategies that result in the equitable receipt of COVID-19 vaccinations among persons with disproportionately higher hospitalizations rates, including non-Hispanic Black adults, is an urgent public health priority.

Effectiveness of mRNA Vaccination in Preventing COVID-19-Associated Invasive Mechanical Ventilation and Death: CDC released an MMWR on the effectiveness of mRNA vaccination in preventing COVID-19-associated invasive mechanical ventilation and death in the United States from March 2021 – January 2022. COVID-19 mRNA vaccines provide protection against COVID-19 hospitalization among adults. However, how well mRNA vaccines protect against the most severe outcomes of COVID-19–related illness, including use of invasive mechanical ventilation (IMV) or death, is uncertain. Receiving 2 or 3 doses of an mRNA COVID-19 vaccine was associated with a 90% reduction in risk for COVID-19–associated IMV or death. Protection of 3 mRNA vaccine doses during the period of Omicron predominance was 94%. COVID-19 mRNA vaccines are highly effective in preventing the most severe forms of COVID-19. CDC recommends that all persons eligible for vaccination get vaccinated and stay up to date with COVID-19 vaccination.
Marvin B. Figueroa, Director
U.S. Department of Health and Human Services
Intergovernmental and External Affairs
200 Independence Ave., S.W.
Washington, D.C. 20201

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HHS OIG Report on Telehealth for Medicare Beneficiaries in COVID-19

Written by AAA Staff on . Posted in Operations, Patient Care, Regulatory.

From HHS Office of Inspector General on March 15, 2022

Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 Pandemic

03-15-2022 | OEI-02-20-00520 | Complete Report

WHY WE DID THIS STUDY

The COVID-19 pandemic created unprecedented challenges for how Medicare beneficiaries accessed health care. In response, the Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) took a number of actions to temporarily expand access to telehealth for Medicare beneficiaries. CMS allowed beneficiaries to use telehealth for a wide range of services; it also allowed beneficiaries to use telehealth in different locations, including in urban areas and from the beneficiary’s home.

This data brief provides insight into the use of telehealth in both Medicare fee-for-service and Medicare Advantage during the first year of the COVID-19 pandemic, from March 2020 through February 2021. It is a companion to a report that examines the characteristics of beneficiaries who used telehealth during the pandemic. Another report in this series identifies program integrity concerns related to telehealth during the pandemic. Understanding the use of telehealth during the first year of the pandemic can shed light on how the temporary expansion of telehealth affected where and how beneficiaries accessed their health care. This information can help CMS, Congress, and other stakeholders make decisions about how telehealth can be best used to meet the needs of beneficiaries in the future.

HOW WE DID THIS STUDY

We based this analysis on Medicare fee-for-service claims data and Medicare Advantage encounter data from March 1, 2020, to February 28, 2021, and from the prior year, March 1, 2019, to February 29, 2020. We used these data to determine the total number of services used via telehealth and in-person, as well as the types of services used. We also compared the number of services used via telehealth and in-person during the first year of the pandemic to those used in the prior year.

WHAT WE FOUND

Over 28 million Medicare beneficiaries used telehealth during the first year of the pandemic. This was more than 2 in 5 Medicare beneficiaries. In total, beneficiaries used 88 times more telehealth services during the first year of the pandemic than they used in the prior year. Beneficiaries’ use of telehealth peaked in April 2020 and remained high through early 2021. Overall, beneficiaries used telehealth to receive 12 percent of their services during the first year of the pandemic. Beneficiaries most commonly used telehealth for office visits, which accounted for just under half of all telehealth services used during the first year of the pandemic. However, beneficiaries’ use of telehealth for behavioral health services stands out. Beneficiaries used telehealth for a larger share of their behavioral health services compared to their use of telehealth for other services. Specifically, beneficiaries used telehealth for 43 percent of behavioral health services, whereas they used telehealth for 13 percent of office visits.

WHAT WE CONCLUDE

Telehealth was critical for providing services to Medicare beneficiaries during the first year of the pandemic. Beneficiaries’ use of telehealth during the pandemic also demonstrates the long-term potential of telehealth to increase access to health care for beneficiaries. Further, it shows that beneficiaries particularly benefited from the ability to use telehealth for certain services, such as behavioral health services. These findings are important for CMS, Congress, and other stakeholders to take into account as they consider making changes to telehealth in Medicare. For example, CMS could use these findings to inform changes to the services that are allowed via telehealth on a permanent basis.

 

2/17 | ASPR National Advisory Committee on Children and Disasters​

Written by AAA Staff on . Posted in Regulatory.

From ASPR on February 14, 2022

The NACCD will conduct an inaugural p​ublic meeting (virtual) on February 17, 2022. The new advisory committee will be sworn in along with the presentation and discussion of challenges, opportunities, and priorities for national public health and medical preparedness, response and recovery, specific to the needs of children and their families in disasters.

Members of the public may attend the meeting via Zoom teleconference, which requires pre-registration, and may provide written comments, submit questions to the NACCD, and provide comments after the meeting by email to NACCD@hhs.​gov.

Draft Agenda
Register

Notice on Ground Ambulance and Patient Billing Advisory Committee

Written by Tristan North on . Posted in Executive, Government Affairs, News, Regulatory.

The Centers for Medicare and Medicaid Services (CMS) has filed for publication in the Federal Register the Solicitation of Nominations Notice for the Ground Ambulance and Patient Billing (GAPB) Advisory Committee. The Notice is scheduled to be included in the Federal Register for tomorrow, Tuesday, November 23.

The Congress created the GAPB Advisory Committee as part of The No Surprises Act enacted last year and currently being implemented by the Departments of Health and Human Services, Labor and the Treasury. The American Ambulance Association, International Association of Fire Chiefs, International Association of Fire Fighters, National Association of Emergency Medical Technicians, and the National Volunteer Fire Council successfully advocated that the Congress take into consideration the unique characteristics of ground ambulance services when determining balance billing policy for our services. The Congress excluded ground ambulance services from the provisions of The No Surprises Act and created the GAPB Advisory Committee to address balance billing.

The AAA has identified candidates, including AAA President Baird, who we will be supporting for inclusion on the Advisory Committee who we believe are well-positioned to represent the AAA membership. Once formed, the Advisory Committee has 180 days in which to report its recommendations to the Congress. The directive of the Committee is to review options to “improve the disclosure of charges and fees for ground ambulance services, better inform consumers of insurance options for such services, and protect consumers from balance billing.” We will be keeping the AAA membership continually informed of the actions and deliberations of the GAPB Advisory Committee.

Should you have any questions regarding the GAPB Advisory Committee, please contact AAA Senior Vice President of Government Affairs Tristan North. He can be reached at tnorth@ambulance.org.

It’s Time for EMS to Apply for HHS Provider Relief Fund Tranche 4!

Written by AAA Staff on . Posted in Executive, Finance, Legislative, Regulatory, Reimbursement.

Recorded October 8, 2021 | Free to All | Speaker: Asbel Montes

The deadline for Provider Relief Fund (PRF) applications is 11:59 PM October 26, 2021. If your EMS agency has not yet applied for funds, the American Ambulance Association strongly encourages you to do so! We are happy to answer member questions, just email hello@ambulance.org. Remember, Amber cost data collection software (www.emsamber.com) access is included with your AAA membership and has a PRF module to help you with your application. If you are an AAA member and need help accessing Amber, email shilker@ambulance.org. HRSA is also hosting a technical assistance webinar for PRF applications on October 13, 2021.

OCR Issues Guidance on HIPAA, COVID-19 Vaccinations, and the Workplace

Written by Scott Moore on . Posted in Human Resources, News.

Today, the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) issued guidance to help the public understand when the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule applies to disclosures and requests for information about whether a person has received a COVID-19 vaccine.

In the guidance, OCR reminds the public that the HIPAA Privacy Rule does not apply to employers or employment records. The HIPAA Privacy Rule only applies to HIPAA covered entities (health plans, health care clearinghouses, and health care providers that conduct standard electronic transactions), and, in some cases, to their business associates.  The HIPAA Privacy Rule applies to most EMS providers but only as it relates to it’s patient’s Protect Health Information (PHI).

Today’s guidance addresses common workplace scenarios and answers questions about whether and how the HIPAA Privacy Rule applies. The Privacy Rule does not apply when an individual:

  • Is asked about their vaccination status by a school, employer, store, restaurant, entertainment venue, or another individual.
  • Asks another individual, their doctor, or a service provider whether they are vaccinated.
  • Asks a company, such as a home health agency, whether its workforce members are vaccinated.

Generally, the Privacy Rule does not regulate what information can be requested from employees as part of the terms and conditions of employment that an employer may impose on its workforce

The Privacy Rule does not prohibit a covered entity or business associate from requiring or requesting each workforce member to:

  • Provide documentation of their COVID-19 or flu vaccination to their current or prospective employer.
  • Sign a HIPAA authorization for a covered health care provider to disclose the workforce member’s COVID-19 or other vaccination record to their employer.
  • Wear a mask–while in the employer’s facility, on the employer’s property, or in the normal course of performing their duties at another location.
  • Disclose whether they have received a COVID-19 vaccine in response to queries from current or prospective patients.

OCR stated that they are issuing this guidance to help consumers, businesses, and health care entities understand when HIPAA applies to disclosures about COVID-19 vaccination status and to ensure that they have the information they need to make informed decisions about protecting themselves and others from COVID-19.

More details about the latest guidance on HIPAA, COVID-19 Vaccinations, and the Workplace may be found at https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/hipaa-covid-19-vaccination-workplace/index.html.  If you have questions regarding what information you may or may not share relative to COVID-19 vaccinations, please contact the AAA for assistance.

 

Application Open: COVID-19 Provider Relief Funding

Written by AAA Staff on . Posted in Executive, Finance, Legislative, Regulatory.

From HHS on September 29, 2021

The Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), has announced a new application cycle for $25.5 billion in COVID-19 provider funding. Applicants will be able to apply for both Provider Relief Fund (PRF) Phase 4 and American Rescue Plan (ARP) Rural payments during the application process. PRF Phase 4 is open to a broad range of providers with changes in operating revenues and expenses. ARP Rural is open to providers who serve rural patients covered by Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP).
See a detailed list of eligible provider types here.
The application is open now and will close on October 26, 2021 at 11:59 p.m. ET. Providers who have previously created an account in the Provider Relief Fund Application and Attestation Portal and have not logged in for more than 90 days will need to first reset their password before starting a new application. In order to streamline the application process and minimize administrative burdens, providers will apply for both programs in a single application.
HHS recently hosted a briefing session to provide information about these upcoming funding opportunities – view the video here. HRSA will also host webinar sessions featuring guidance on how to navigate the application portal. Register now using the links below.
  • Thursday, September 30 from 3:00 – 4:00 p.m. ET
  • Tuesday, October 5 from 3:00 – 4:00 p.m. ET
  • Two additional webinars the weeks of October 11th and 18th (dates, times, and registration forthcoming)
 
Real time technical assistance is available by calling the Provider Support Line at (866) 569-3522, for TTY dial 711. Hours of operation are 8 a.m. to 10 p.m. CT, Monday through Friday.

HHS PRF Tranche 4 | Important Funding Opportunity for EMS Providers

Written by Scott Moore on . Posted in Executive, Finance, Legislative, Regulatory, Webinars.


Speaker: Scott Moore, Esq. | Share on Facebook
This funding opportunity will distribute $25.5 billion in additional Phase 4 General Distribution for EMS agencies and American Rescue Plan (ARP) payments for qualified rural providers who furnish services to Medicaid/CHIP and Medicare beneficiaries. It is critical for all #EMS providers to apply for this funding opportunity regardless of previous funding allocations. We have learned that many EMS providers did not apply for the Tranche 3 funding opportunity because they did not believe that they would be eligible to receive funds under the announced funding formula. Due to the limited number of applicants in Tranche 3, HRSA modified the formula and many who failed to apply would have received funds. We are recommending that all EMS agencies apply to receive the funding that they desperately need. The deadline for applying is 11:59 p.m. on October 26, 2021. There is no penalty for applying.

HHS Provides More Details on Phase 4 and Rural Provider Relief Fund Distribution

Written by Kathy Lester on . Posted in Government Affairs.

As previously reported by the AAA, the Department of Health and Human Services (HHS) has announced that it will open on September 29, Phase 4 of the Provider Relief Fund (PRF) to allocate $17 billion dollars for COVID-19 relief. In addition, it will provide $8.5 billion specifically for rural providers. On September 15, HHS held a stakeholder call on the PRF in which the agency provided more details on the distribution.

The application process will remain open for 4 weeks. Providers will be able to use the funding through December 31, 2022.  The Administration’s goal is to release the rural funds before Thanksgiving and the Phase four funds by mid-December 2021. The agency indicated it has additional funding it is holding back to reimburse for the uncompensated care fund for which providers and suppliers can still apply.

The AAA has been advocating relentlessly for the Administration to open a fourth phase of funding and support rural providers and suppliers.  As described below, these phases of funding will rely upon data from Medicare, Medicaid, and the State Children’s Health Insurance Program (CHIP).  It is important that all AAA members who qualify not only submit applications, but also make sure that you have appropriately submitted claims to these programs, including when allowed, claims under the ground ambulance treatment in place waiver. We strongly recommend that all AAA members apply for funding.

Phase 4 Funding

The Phase 4 PRF methodology and application will primarily follow the same rules set forth for Phase 3.  It will apply for Q2 2020 through Q1 2021.  The funding will be available for the same broad set of providers and suppliers that were eligible under Phase 3.

Phase 4 will have two components.  The Acting Administrator of HRSA has explained that 75 percent of the funding for Phase 4 will be determined based on a provider’s lost revenues and expenses that the provider submits through the application process.  HRSA will calculate the amount awarded based on the number of applications received.  However, it will establish a base for all providers and then adjust that base up for medium and small providers who have lower volumes over which to spread their costs.  The determination of provider size will be based on patient revenues.

The second component of Phase 4 funding will allocate 25 percent for bonus payments to providers serving Medicare, Medicaid, and CHIP patients.  The final amounts awarded will be determined based on the volume of services provided to these patient populations.

The Acting Administrator also noted that once again providers who have higher values compared to their peer group will be flagged and may have the amount they receive capped or may not receive any funding.  There will be a reconsideration process for these providers as well.

Rural Funding

In addition to Phase 4, HRSA will provide rural-specific relief to providers and suppliers serving rural patients.  The determination of whether a provider qualifies will be based on the patient’s location, not that of the providers.  HRSA will use Medicare, Medicaid, and CHIP data to calculate the payment, so the application process will be simplified and providers required to submit less information.  The amounts will be determine based on the number of patients served and the number of applicants.

Additional Relief

The Acting Administrator also indicated that HRSA will provide a 60-day grace period for those providers who received funds already and are required to report if they cannot meet the current reporting deadline.  She also noted that HRSA is establishing a reconsideration process for Phase 3 as well.  Details will be available on the HRSA website.

Additional Information

HRSA will be posting information on its website.  It will also host two webinars on September 30 and October 5 to provide more information about how providers can apply to these programs.

HHS: Availability of Add’l $25.5 Billion in COVID-19 Provider Funding

Written by Scott Moore on . Posted in Advocacy Priorities, Executive, Government Affairs, Legislative, Regulatory.

HHS Announces the Availability of $25.5 Billion in COVID-19 Provider Funding

This morning the Department of Health and Human Services (HHS) announced that it will be making $25.5 billion in new funding available for healthcare providers affected by the COVID-19 pandemic. The funding, available through the Health Resources and Services Administration (HRSA) will include $8.5 billion in American Rescue Plan Act (ARPA) resources for providers who serve rural Medicaid, Children’s Health Insurance Program (CHIP), or Medicare patients, and an additional $17 billion for Provider Relief Fund (PRF) Phase 4 for a broad range of providers who can document revenue loss and expenses associated with the pandemic.

Getting additional financial relief for ground ambulance service providers who are still struggling from the lost revenue and increased expenditures resulting from being on the frontlines of responding to the pandemic has been a top priority for the AAA. The AAA along with the International Association of Fire Chiefs, International Association of Firefighters, National Associations of EMTs and National Volunteer Fire Association have continually pressed HHS to release the remaining funds. We strongly encourage all AAA members to submit an application regardless of whether you have applied for previous rounds of funding.

Consistent with the requirements included in the Coronavirus Response and Relief Supplemental Appropriations Act of 2020, PRF Phase 4 payments will be based on providers’ lost revenues and expenditures between July 1, 2020, and March 31, 2021 (Q3 – Q4 2020 and Q1 2021). The PRF Phase 4 will reimburse smaller providers, who tend to operate on thin margins and often serve vulnerable or isolated communities, for their lost revenues and COVID-19 expenses at a higher rate compared to larger providers. PRF Phase 4 will also include bonus payments for providers who serve Medicaid, CHIP, and/or Medicare patients, who tend to be lower- income and have greater and more complex medical needs. HRSA will price these bonus payments at the generally higher Medicare rates to ensure equity for those serving low-income children, pregnant women, people with disabilities, and seniors.

Consistent with the focus of the ARPA, HRSA will make ARPA rural payments to providers based on the amount of Medicaid, CHIP, and/or Medicare services they provide to patients who live in rural areas as defined by the HHS Federal Office of Rural Health Policy. As rural providers serve a disproportionate number of Medicaid and CHIP patients who often have disproportionately greater and more complex medical needs, many rural communities have been hit particularly hard by the pandemic. Accordingly, ARP rural payments will also generally be based on Medicare reimbursement rates.

In the announcement, HHS stated that it would “expedite and streamline” the application process and minimize administrative burdens, providers will apply for both programs in a single application. HRSA will use existing Medicaid, CHIP and Medicare claims data in calculating payments. The application portal will open on September 29, 2021. HHS has stated that to ensure that these provider relief funds are used for patient care, PRF recipients will be required to notify the HHS Secretary of any merger with, or acquisition of, another health care provider during the period in which they can use the payments. They have stated that providers who report a merger or acquisition may be more likely to be audited to confirm their funds were used for coronavirus-related costs.

To promote transparency in the PRF program, HHS also released detailed information about the methodology utilized to calculate PRF Phase 3 payments. Providers who believe their PRF Phase 3 payment was not calculated correctly according to this methodology will now have an opportunity to request a reconsideration. HHS announced that additional details on the PRF Phase 3 reconsideration process will be released at a later date.

In addition, many of you attended the PRF Reporting Q&A AAA webinar yesterday with Asbel Montes, Brian Werfel, and Scott Moore.  HHS has acknowledged the challenges facing many providers across the country due to recent natural disasters and the Delta variant, HHS announced a final 60-day grace period to help providers come into compliance with their PRF Reporting requirements if they fail to meet the deadline on September 30, 2021. While the deadlines to use funds and the Reporting Time Period will not change, HHS will not initiate collection activities or similar enforcement actions for non-compliant providers during this grace period.

Members can access more information about eligibility requirements, the documents and information providers will need to complete their application, and the application process for PRF Phase 4 and ARP Rural payments by visiting the HRSA website.

The combined application for American Rescue Plan rural funding and Provider Relief Fund Phase 4 will open on September 29, 2021.  Like we have done with the previous rounds of HHS funding, we encourage all ambulance service providers to submit an application for this Phase 4 funding.  If you have questions regarding this or any COVID-19 related questions, please contact hello@ambulance.org.

HHS/ASPR Project ECHO COVID-19 Clinical Rounds

Written by AAA Staff on . Posted in Operations, Patient Care, Regulatory.

From HHS/ASPR – Project ECHO COVID Clinical Rounds

COVID-19 CLINICAL ROUNDS
A Peer-to-Peer Virtual Community of Practice

We Are Back!
Thank you for your support in the HHS/ASPR – Project ECHO COVID Clinical Rounds.To sign up for emails regarding upcoming HHS/ASPR COVID-19 sessions, please click here!
You will be redirected to a page that will allow you to opt into an email list serve that will keep you up to date with our weekly sessions. 

Resources from past sessions are below
*Regional Ebola and Other Special Pathogen Treatment Centers
Massachusetts General Hospital (Boston, Massachusetts)
New York City Health and Hospitals Corporation/HHC Bellevue Hospital Center (New York City, New York)
Johns Hopkins Hospital (Baltimore, Maryland)
Emory University Hospital and Children’s Healthcare of Atlanta/Egleston Children’s Hospital (Atlanta, Georgia)
University of Minnesota Medical Center (Minneapolis, Minnesota)
University of Texas Medical Branch at Galveston (Galveston, Texas)
Nebraska Medicine – Nebraska Medical Center (Omaha, Nebraska)
Denver Health Medical Center (Denver, Colorado)
Cedars-Sinai Medical Center (Los Angeles, California)
Providence Sacred Heart Medical Center and Children’s Hospital (Spokane, Washington)
Resources

AAMC COVID-19 Clinical Guidance Repository:
https://www.aamc.org/covid-19-clinical-guidance-repository

ASPR’s Technical Resources, Assistance Center, and Information Exchange (TRACIE) Novel Coronavirus Resources:
https://asprtracie.hhs.gov/covid-19

CDC COVID-19 Resources for Health Care Professionals:
https://www.cdc.gov/coronavirus/2019-ncov/hcp/index.html

NETEC, the National Emerging Special Pathogen Training and Education Center:
https://netec.org/

SCCM COVID-19 Guidelines:
https://www.sccm.org/SurvivingSepsisCampaign/Guidelines/COVID-19

WHO COVID-19 Technical Guidance:
https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance

WHO COVID-19 Situation Reports:
https://www.who.int/emergencies/diseases/novel-coronavirus-2019/situation-reports

Please be mindful of COVID-2019 infection prevention and control, try to limit numbers of people joining this learning session from one gathering place and practice social distancing.
WHO guidance on getting workplaces ready for COVID-2019

Special Sessions

Transitions of Care – August 4
Update on Remdesivir and Dexamethasone – Oct 1
Home Health, EMS, Emergency Department and Critical Care – Oct 29

Monoclonal Antibodies – Dec 3

Crisis Care Update – Dec 10

100th Session – Dec 15

For resources and recordings of earlier sessions, visit the Project ECHO website
COVID-19 Clinical Rounds: Critical Care Resources

Feb 2 – System Level Surge Staffing and Resilience Strategies

Jan 26 – System Level Surge Capacity: Crucial Strategies

For earlier presentations and recordings, please visit the Project ECHO COVID-19 Webpage
COVID-19 Clinical Rounds: Emergency Department Resources

Feb 4 – ED Update

Jan 28 – ED Nursing Update

For earlier presentations and recordings, please visit the Project ECHO COVID-19 Webpage
COVID-19 Clinical Rounds: EMS Resources

Feb 1 – EMS Involvement in Monoclonal Antibody Infusion Programs

Jan 25 – COVID-19 and Riots

For earlier presentations and recordings, please visit the Project ECHO COVID-19 Webpage
Please direct any additional questions or concerns to
C19echo@salud.unm.eduFor help with connecting, please call (505) 750-4897 or email echoit@salud.unm.edu
ECHO is a movement to demonopolize knowledge and amplify the capacity to provide best practice care for underserved people all over the world.

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