Radiologists have been testing and treating COVID-19 patients for the past few months. New legislation like the Families First Coronavirus Act (FFCRA) has changed how physicians will receive reimbursement for their work. This article is meant to discuss the acts put in place by the government and actions to take as a provider.
FFCRA & CARES
The first Act to consider is the Families First Coronavirus Response Act, which was signed on March 18th, 2020. The FFCRA will shortly be put into action for claim reimbursement. This act provides $1 billion in reimbursement to providers for coronavirus testing and treatment for the uninsured. Insured patients are also covered by the FFCRA as private insurers will be waiving patient cost-sharing.
The second Act to consider is the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Part of the $100 billion dollar funding of CARES Act will be used to support healthcare-related expenses of uninsured individuals with COVID-19. It is important to note that both the CARES Act and FFCRA are limited to the funds in the acts. However, the CARES Act is 100 times larger, making the CARES Act the main source to receive reimbursement from the government.
Through FFCRA, the Department of Health & Human Services (HHS) "will provide claims reimbursement to health care providers generally at Medicare rates for testing uninsured patients for COVID-19 and treating uninsured patients with a COVID-19 diagnosis". Radiologists will be reimbursed via direct deposit for testing for COVID-19 performed on or after February 4th, 2020. This reimbursement will be provided by electronic submission to the HHS.
For insured patients, the Families First Coronavirus Response Act requires "private insurers to waive an insurance plan member's cost-sharing payments for COVID-19 testing". Humana, Cigna, UnitedHealth Group, and the Blue Cross Blue Shield system are committed to waiving cost-sharing payments for treatment due to COVID-19 for their members.
How Does a Provider Participate in FFCRA?
If a provider would like to participate in reimbursement for uninsured patients, then the provider must:
- Check to see if the patient is uninsured and has no health care coverage eligibility. This includes individual, employer-sponsored, Medicare and Medicaid coverage or any other type of coverage.
- Agree to the defined program reimbursement as payment in full.
- Agree to not balance bill the patient.
- Agree to program terms and conditions.
- Agree to being subject to a post-reimbursement audit review.
FFCRA Reimbursement & COVID-19
It is important to note that reimbursement through FFCRA is COVID-19 specific. Meaning testing and treatment of other illness are not covered in this Act for the uninsured.
According to the HRSA, "specimen collection, diagnostic and antibody testing" are considered qualifying tests for the novel coronavirus. An uninsured patient is still liable for any test beyond this to determine other illness or diseases. For example, if a radiologist provides a chest CT to help determine if the patient has COVID-19 then this would be covered. However, if the patient tests are negative for COVID-19 then all other testing and treatment would need to be paid by the uninsured patient.
When a patient receives treatment, but does not have coronavirus. Is this covered by FFCRA? Treatment would not be covered by Medicare, if coronavirus is not the primary diagnosis. The HRSA states, "any treatment without a COVID-19 primary diagnosis, except for pregnancy when the COVID-19 code may be listed as secondary" will be excluded from payment from Medicare. The treatment cost would be paid by the patient, if they do not have coronavirus and receives treatment for some other condition, illnesses, or disease. As the FFCRA only covers COVID-19 related testing and treatment, make sure that your uninsured patients are aware of what they will be liable for payment.
CARES Act Reimbursement
The second Act that affects provider reimbursement is the CARES Act Provider Relief Fund. The CARES Act provides $100 billion in relief to hospitals and providers. The HHS states that the purpose of this program is "to support healthcare-related expenses or lost revenue attributable to COVID-19". The HHS has already provided 30 billion as of Friday, April 24th to eligible providers.
Determining Eligibility for the CARES Act
According to the HHS, any provider is eligible who:
- Have Received Medicare fee-for-service (FFS) reimbursements in 2019
- Must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
- Are within heavily impacted areas of the COVID-19 pandemic and who are struggling to keep their doors open due to healthy patients delaying care and cancelled elective services
This distribution will be provided in different avenues depending on if you are a large organization, employed Radiologist, part of a Radiology group, or a single Radiologist.
What if I am a part of a radiology group?
Radiology groups will receive the relief fund payment as the billing organization. Radiologists within the group should reach out to their in-house billing team or their billing partner like Dexios to identify the accounts where they should expect relief payments.
What if I am a single radiologist and not a part of a group?
Radiologists will receive a payment under the Tax Identification Number (TIN) used to bill Medicare.
If you want to request for distribution payment through the CARES Act, follow this guide provided by the HHS. This guide will break down the necessary steps on how to determine if you are able to receive this type of relief and how to receive your part of the distribution.
Additional Funds through CARES ACT
Radiologists that have already received money from the Provider Relief Fund are able to apply for additional funds. This can done via the Provider Relief Fund Application Portal. Providers will need to submit data about the Radiology Groups' annual revenues and estimated COVID-related losses. These additional funds are for providers that have already received part of the initial $30 billion in distribution funds. Providers who have "NOT yet received any payments from the Provider Relief Fund may still receive funds in other distributions", but should not use the General Distribution Portal.
Who is eligible to receive additional payments?
According to the HHS, "any provider who has already received a payment from the Provider Relief Fund as of 5:00 pm EST Friday, April 24" can receive additional funds the Provider Relief Fund Application Portal.
For more information on the CARES ACT distribution and additional funds, see this FAQ provided by the HHS.
The government has put in place several acts to assist patients and healthcare providers during this pandemic. As a provider, it is important to know the type of reimbursements that you can receive from the government. It is equally important to educate your uninsured patients and make them aware of costs that can incur, if they do not have coronavirus. Overall, the FFCRA seems to provide uninsured the ability to receive free healthcare, if and only if the patient is being tested for or has COVID-19. The CARES Act will be covering a large portion of reimbursement as the FFCRA will likely deplete quickly.