What the End of the Public Health Emergency Means for Home Health Billing

The COVID-19 Public Health Emergency (PHE) is ending as of May 11, 2023, and home health billing leaders should be preparing. 

While there is some time left, the transition won’t be as clear cut as many might think, with some waivers and reimbursements changing immediately and others taking place over the coming months and years. This means that now is an excellent time to start gathering information and creating a plan to transition your home health billing practices out of an active pandemic and into the new normal that’s coming around the corner. 

To get you started, we suggest the provider-specific fact sheet presented by The Centers for Medicare & Medicaid Services (CMS), specifically for home health agencies, which we’re reviewing here [1].

Reimbursements for multiple methods of addressing the pandemic will be phasing out as the PHE ends. 

COVID-19 vaccines will continue to be reimbursed by CMS at about $40 per dose when rendered in outpatient settings to Medicare beneficiaries. This is through the end of the calendar year. Starting January first of the year when the Emergency Use Authorization (EUA) ends, the payment will be aligned with the rate for administering other Part B vaccines at around $30 per dose. 

Home health billing leaders should also be aware that the payment for administering the vaccine in the patient home is changing. Starting in 2023, CMS is paying about $36 on top of the standard administration amount to administer COVID-19 vaccines for certain Medicare patients in their home. Beginning on January 1, 2023, CMS will update the additional in-home payment rate for COVID-19 vaccine administration annually to properly reflect changes in costs. After the end of the PHE, CMS will pay about $76 per dose to administer the vaccine in the home for certain Medicare patients. This payment will not be impacted by the end of the PHE. 

In terms of monoclonal antibodies, home health care billing leaders will want to make note – starting from the EUA declaration for drugs and biologicals for COVID-19, CMS will reimburse for monoclonal antibodies at the rate paid for biological products through the applicable payment system.

Home health agencies have enjoyed increased flexibility in using telehealth technology within the 30-day period of care during the pandemic. The provisions from Medicare are permanent beyond the end of the COVID-19 PHE. Home health billing personnel should keep in mind though, that home health services that are provided using telecommunication systems must be included on the home health claim as of July 1, 2023.

Additionally, the home health face-to-face encounter that’s required can be conducted via telehealth when the patient is in their home. Though the PHE is ending, the Consolidated Appropriations Act (CAA) supports an extension of the allowance of the home as an originating site, an extension that will stretch through December 31, 2024. 

You’ll also find flexibility in provider enrollment for telehealth. CMS has allowed practitioners to provide telehealth services from their home with no need to report the home address on enrollment while still billing from their currently enrolled location. This waiver will extend beyond the end of the PHE, through Dec 31, 2023.

You’ll find that there are multiple points intended to reduce administrative burden for home health billing. For example, the definition of “homebound” is unchanged, still representing a beneficiary whose physician has advised that they not leave their house because of suspected or confirmed COVID-19 diagnosis as well as if a patient is known to have a condition that makes them more likely to contract COVID-19. Home health agencies (HHA) can still provide these services under the Medicare Home Health Benefit and the definition will not be shifted as a result of the COVID-19 PHE. 

At the same time, information sharing is changing. CMS has waived requirements to provide detailed discharge planning information to patients, caregivers, or a patient representative when selecting a post-acute care provider. This waiver was a temporary effort to speed discharge and residents moving between care settings. While CMS is maintaining all other discharge planning requirements, the information sharing waiver will end with the PHE. Other changes include:

• The provision that allows Medicare-eligible home health patients to fall under the care of a clinical nurse specialist, nurse practitioner, or physician assistant and to do so in a way that allows for faster initiation of services for home health patients has been made permanent beyond the public health emergency and has been codified in regulations. 
• The waiver that allows HHAs ten business days to provide a patient clinical record instead of four will end along with the COVID-19 PHE. 
• The waiver for training and assessment of aids which requires a registered nurse or other appropriate skilled professional to make an onsite annual supervisory visit for each aid will end when the PHE expires. Any postponed assessments have to be completed within 60 days of the end of the PHE. 

Reporting Waivers Are Disappearing but Appeals Continue

Home health leaders should know that CMS is ending waivers around OASIS transmission along with the end of the PHE. At the same time, flexibilities around Medicare appeals in Traditional Medicare, Medicare Advantage, and Part D will continue to apply, consistent with existing authority. Requests for appeals must also meet existing regulatory requirements. 

These changes are just a sample of the shifts that home health billing leaders should be keeping up with. We encourage you to review the fact sheet thoroughly with any questions or concerns you might have. And if you believe you might need support in home health care billing as these processes become more complex, please contact us whenever you’re ready.