As we all know many flexibilities spawned out of the Covid 19 pandemic. Easing of documentation, physician licensures, patient co-pays and more. These changes were created to make the health care provider's life easier - yet with that being said - this convenience comes with a price. The price is costly if providers don't develop good historical record keeping of CMS regulatory and policy flexibilities. Save all CDC & CMS policy/regulatory temporary flexible changes in safe keeping or attach to patient records.
Example: providers need to keep records that document the justification for
portable exams being done on Covid-19 patients in order to reduce disease spread - that would not otherwise be considered medically necessary. "
It may be difficult to find time to specifically organize these historical materials now, but rest assured, it will be important later. If the above information can be preserved, it will save time and expense in the future. This evidence will certainly aide in responding to any type of documentation discrepancies or criticisms of the health care during the COVID-19
pandemic."
Save documentation (to include dates) of temporary CDC & CMS policies, waivers, and flexibilities-along with CDC guidelines for preventing Covid-19.
Per Physician News Digest...."
Medical staff duties and clinical privileges that have been expanded or changed temporarily during this period may be needed later to clarify the record. If nurse practitioners have been given greater independence or a staff member’s responsibilities have shifted from administrative to clinical, that information may be forgotten. When examining the record at a later date, these new responsibilities may explain why information was documented by a certain person. If not already documented, whenever a person’s typical role has changed or enlarged, it should be demonstrated in writing for later use."
"This plan sets forth the four goals that drive the Office of Inspector General’s (OIG’s) strategic planning and mission execution with respect to HHS’s COVID-19 response and recovery. These goals are to
(1) protect people,
(2) protect funds,
(3) protect infrastructure, and
(4) promote effectiveness of HHS programs—now and into the future.
.... OIG is using risk assessment and data analytics to identify, monitor, and target potential fraud, waste, and abuse affecting HHS programs and beneficiaries and to promote the effectiveness of HHS’s COVID-19 response and recovery programs.
....OIG uses "expert staff and modern tools and technologies, including artificial intelligence, to detect trends and patterns of suspicious activity and to shape and strengthen our oversight and enforcement. As appropriate and feasible, we share data analytics and technical assistance with HHS officials to strengthen program integrity, effectiveness, and management practices. Further, we are coordinating our work with key oversight and law enforcement partners, including the Pandemic Response Accountability Committee (PRAC); Federal, State, local, and Tribal entities; and the Government Accountability Office, among others, to ensure adequate oversight, avoid duplication, and share insights."
June 19, 2020 MLN SE20011 provides guidance on modifiers, waivers, flexibilities, non covered tests and ABNs
This issue updates the prior MLN by adding guidance to coverage of Covid-19 testing and special considerations when delivering an ABN during the pandemic.
as per CMS: Starting on July 6, 2020, and for the duration of the public health emergency, consistent with sections listed below of CDC guidelines titled, “Interim SARS-CoV-2 Testing Guidelines for Nursing Home Residents and Healthcare Personnel,”
Original Medicare and Medicare Advantage plans will cover diagnostic COVID-19 lab tests and non-cover tests not considered diagnostic.
Tests that are considered non-diagnostic are not covered.
Special considerations are outlined for delivery of ABNs during the pandemic.
as per CMS: 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 be 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.
From Emergency Care Journal
"Lung ultrasound is a reasonable tool for detection of manifestations of COVID-19, to facilitate the division of patients flow of infected with SARS-CoV-2 from those affected by other pathologies. Often, a reason for the incorrect separation of the flows is the possibility of false-negative rRT-PCR results. We aimed to evaluate the advantages of performing Lung Ultrasound (LUS) in patients with a negative swab, to confirm the suspicious of COVID-19 at the bedside, according to the recent findings of typical lung ultrasound lesions of COVID19 related pneumonia.
We analyzed 11 non-critical patients admitted to Emergency Department in the Internal Medicine ward, during outbreak, as Covid-19 negative patients affected by pneumonia. The result of the ultrasound findings conditioned the consequent allocation of the patient. 9/11 patients had typical LUS findings for COVID-19, but only 3/11 patients had a second positive nasopharyngeal swab, and 2/11 had positive swab on pleural fluid. 6/11 patients remained negative with strongly suspicious LUS lesions, and so treated and isolated as Covid-19 positive. 2/11 had negative swab and none LUS findings, thus treated as affected by other pathologies. These findings clearly show how LUS plays an important role together with the chest x-ray in identifying patients with interstitial pneumonia from COVID-19"
At university of Utah Health
Portable x-ray machines are being used to take chest x-rays through the glass of observation rooms containing suspected (or confirmed) COVID-19 patients.
Radiologists and radiologic technologists at University of Utah Health are doing their part to minimize the chance of COVID-19 spreading while at the same time conserving precious Personal Protective Equipment (PPE). They’re using an innovative technique at University Hospital for taking x-rays of patients with respiratory illnesses. In order to keep suspected COVID-19 patients safely in negative pressure observation rooms, they obtain x-ray images with a portable x-ray machine through the glass wall of the room. (scroll to bottom of page for instructional video)
“With some minor technical modifications, chest x-rays taken through the glass are just as clear as normal x-rays,” states Phuong-Anh Duong, MD, Associate Professor of Radiology. Duong, along with her colleagues in the Cardiothoracic Imaging Section, Joyce Schroeder, MD (Section Chief), and Howard Mann, MD, brought the idea to Alex Nieves, MPA, the Manager of Diagnostic Radiology services at the hospital. Together, they tested the new setup and were pleased with the results.
