CDC releases new guidelines for vaccinated healthcare staff: Your COVID-19 Briefing
In this edition
Use the links listed below to jump between sections.
NEWS
Dimming prospects for herd immunity
Innovation at work: The next generation of COVID-19 vaccines
The Senate reintroduces the HEAT Act
Home- and community-based care legislation
COMPLIANCE
CLINICAL
ADMINISTRATIVE
Please note
The views, information, and guidance in this resource are provided by the author and do not necessarily reflect those of WellSky. The content provided herein is intended for informational purposes only. The information may be incomplete, and WellSky undertakes no duty to update the information. It is shared with the understanding that WellSky is not rendering medical, legal, financial, accounting, or other professional advice. WellSky disclaims any and all liability to all third parties arising out of or related to this content. WellSky does not make any guarantees or warranties concerning the information contained in this resource. If expert assistance is required, please seek the services of an experienced, competent practitioner in the relevant field. WellSky resources are not substitutes for the official information sources on COVID-19. Providers should continue to track developments on official CMS and CDC pages, including:
CMS response to Coronavirus and latest program guidance
CDC interim infection prevention and control recommendations
Current Cases and Maps
Spring is here, and things are looking up at long last. As stated in last month’s edition of the COVID-19 Briefing, the U.S. added approximately 65,000 COVID-19 cases a day through most of March and early April. As we enter May, the average daily case count has declined 27%, with an average of 49,000 cases per day. The graph below from the New York Times tells the story as new cases decline.
As of May 3, a total of 32,448,723 people in the U.S. have been infected with COVID-19. More than 576,000 have perished from the disease. Even with welcome improvements, the numbers are staggering.
In the meantime, providers across the country are administering approximately 2.4 million vaccinations each day. Throughout most of April, daily vaccination volumes were above 3 million, but have been dropping as demand declines. On May 2, the Centers for Disease Control and Prevention (CDC) announced that 147 million people in the U.S. have been vaccinated with at least one dose of COVID-19 vaccine. More than 104 million people are now considered fully vaccinated, having received the single dose Johnson and Johnson vaccine or both doses of either the Pfizer-BioNTech or Moderna vaccinations.
The stress on hospitals has significantly lessened since February, and while hospitalizations have risen slightly since the beginning of April, they appear to be isolated to areas of the country where outbreaks have recently occurred. According to the CDC, about one in nine hospitals with intensive care units (ICUs) have recently reported census levels of at least 95%. Last week, an average of 71% of all ICU beds were occupied across the country, according to data released by the Department of Health and Human Services (HHS). In comparison, the national average ICU occupancy as measured by the Society of Critical Care Medicine was 67% in 2010.
Thankfully, just as new case counts have declined, the mortality rates related to COVID-19 have also declined. The U.S. is reporting fewer than 700 mortalities per day, which represents a drop of 8%.
The map from the New York Times with identified hot spots is also a much softer hue with only isolated hotspots across the nation. Michigan, Minnesota, Colorado, and parts of Oregon are still grappling with higher numbers of new cases, but the rest of the country appears to be stable at the lower end of the new case spectrum.
The level of risk in most areas, with the exception of Michigan, continues to decrease, although there is still plenty of “very high” risk for COVID-19 transmission nearly everywhere.
A look at the United States in terms of mask mandates and restrictions also underscores the risk level by state. A total of 24 states have no mask mandates in public or indoors. Only one, Colorado, has mixed restrictions, and the other half of the country continues with mask mandates while individuals are indoors.
Finally, while travel within the U.S. seems to be ramping up after a year-long drought, we are again seeing moves from the Administration to limit the entry of travelers from abroad – this time from India where there has been a record surge in cases and where multiple variants of the virus are circulating. The stories out of India have been heartbreaking, with multiple stories of hospitals at the brink and shortages of critical supplies such as oxygen. The ban will not apply to U.S. citizens, permanent residents, or their spouses. Certain humanitarian workers will also be exempt from the ruling. The U.S. is following similar actions as Britain, Canada, Germany, France, and Australia.
News
Dimming prospects for herd immunity
Last year at this time, as state orders limiting business and social activities wore on, we began discussing “herd immunity” – that conceptual moment in time when 60–70% of Americans would be protected from the virus, allowing us to return to “normal.” There has certainly been a lot of controversy around the topic especially when espoused as a political end game. Unfortunately, the prospects of achieving true herd immunity may be dimming.
The New York Times reports many experts are now suggesting that the idea of herd immunity may be unrealistic. The primary reasons are the introduction of more transmissible virus variants and vaccine hesitancy among many Americans. In fact, the B1.1.7 variant first noticed in Britain, and now widely circulating in the U.S., is about 60% more transmissible than the original virus. This means that the percentage of Americans not susceptible to the virus would have to rise to 80% to achieve herd immunity levels. Vaccine hesitancy is an additional concern as about 30% of Americans are reluctant to be vaccinated at all. The map below shows the diversity of expectations around vaccination rates.
Additionally, many countries substantially trail the U.S. when it comes to the percentage of the population already vaccinated. For example, while India contends with a significant new outbreak, less than 2% of its population has been fully vaccinated. All of this suggests that the “virus will most likely become a manageable threat that will continue to circulate in the U.S. for years to come.”
“The virus is unlikely to go away” according to Rustom Antia, an evolutionary biologist at Emory University in Atlanta. “But we want to do all we can to check that it’s likely to become a mild infection.” The New York Times article suggests that this development poses a new public health challenge among some segments of the public, along the lines of “why bother” if herd immunity is not achievable. Others like Dr. Anthony Fauci, now the Administration’s top COVID-19 advisor, suggest that herd immunity was never a real objective and, rather, vaccination levels are the only way to keep serious infections at a manageable level.
According to the article, “if the herd immunity threshold is not attainable, what matters most is the rate of hospitalizations and deaths after pandemic restrictions are relaxed.” If vaccination rates among those who may be most vulnerable continue to rise, there is a modified expectation that in time COVID-19 may become more of a seasonal issue, somewhat like the flu, and will affect mostly the young and healthy.
Even so, there is a real concern that highly contagious variants of the virus will continue to emerge such that “every couple of years” the country could potentially find itself in a “mad scramble” related to virus hot spots. According to Jeffrey Shaman, an epidemiologist at Columbia University, “maybe the general public can go back to not worrying about it so much, but we [epidemiologists] will have to.”
Innovation at work: The next generation of COVID-19 vaccines
The Wall Street Journal reports that your next COVID-19 vaccination might not be a shot in the arm and could come in the form of a pill or nasal spray. Newer vaccines from Sanofi SA, Altimmune, Inc., and Gritstone Oncology, Inc. may also provide longer lasting immune responses and be more successful against new variants of the virus. These new delivery modes could also make it much easier to distribute vaccines in remote areas of the country where delivery of some of the earliest vaccines was challenging due to extreme storage requirements.
Right now, there are only three vaccines approved for use in the U.S. – Pfizer-BioNTech, Moderna, and Johnson & Johnson. There are 277 vaccines in various stages of development across the world, and 93 have entered human testing phases based on information provided by the World Health Organization. Most of the current vaccines are injectable, but there are two that are given orally and seven that are nasal sprays. Most of the testing remains in early stages and it is expected that none of these new products will be available much before late 2021 or 2022. It is hoped that, with more flexible storage requirements, some of the newer vaccines will be more transportable, especially to countries that are currently lagging in the vaccination effort.
Interestingly, the nasal sprays may also induce a protective response known as mucosal immunity which helps clear the virus from the respiratory tract, thereby also reducing transmission by people who have been vaccinated. Currently, none of the vaccines available in the U.S. are thought to be capable of such a claim.
The other interesting twist is that, while we have specifically been cautioned not to mix and match vaccines, research is moving forward to study whether combining multiple vaccines might be more effective than limiting vaccination to a single product. Scientists are starting to consider that some additional vaccines could potentially be used as boosters to lengthen the protection period and serve to block virus variants.
Long story short, we have not heard the last of the vaccine development innovations – there is clearly much more to come.
The Senate reintroduces the HEAT Act
Many readers will recall that in 2020 Senator Susan Collins and a handful of other senators introduced legislation that would enable Medicare reimbursement for telehealth services. The bill didn’t go far as it ran into some opposition on Capitol Hill. The bill has now been reintroduced in the Senate as S. 1309 – the Home Health Emergency Access to Telehealth (HEAT) Act. The National Association for Home Care and Hospice (NAHC) has made the passage of the HEAT Act a top legislative priority for 2021 and is urging providers to contact their congressional delegates to press for passage of the bill this year.
For those new to the debate, a little recent history may be in order. In conjunction with Congress’s passage of the Coronavirus Aid, Relief, and Economic Security (CARES) Act in early 2020, CMS was encouraged to consider ways to allow telehealth as a home health benefit. CMS responded that current law precluded its ability to allow for reimbursement of telehealth services – even during a public health emergency – given the statutory requirement that only in-person visits constitute billable home health services. Enter the proposed legislation which would establish authority for CMS to issue waivers that would enable billing for telehealth services during a public health emergency. Clearly, the bill is limited in scope and does not go as far as many would like, but it is a welcome first step.
Bill Dombi, President of NAHC, noted that “the COVID-19 pandemic has firmly demonstrated the value of telehealth as a tool in meeting the clinical needs of home health patients…however, with the absence of any reimbursement for telehealth, home health agencies have not had the ability to make full use of it.”
This newest iteration of the bill is introduced by the same group of senators – Susan Collins (ME), Ben Cardin (MD), Roger Marshall (KS), and Jeanne Shaheen (NH). NAHC encourages all agencies to reach out to their senators to support the bill as it moves through Congress.
Home- and community-based care legislation
Back in March, several members of Congress proposed a draft bill entitled the HCBS Access Act of 2021 designed to jump start consideration of national standards and requirements for home- and community-based services (HCBS) delivered under the auspices of Medicaid waiver programs. In essence, the bill would establish a permanent benefit as part of each state’s Medicaid program that would be fully funded by the federal government. Currently, there are wide variations among state programs and many who need services find themselves on waiting lists – sometimes for years – before getting the care that is needed. Every state administers its own waiver programs differently and the levels of state support in the form of funding also vary widely. The proposed bill has a number of objectives including the following:
- To establish requirements for home- and community-based services under state plans to ensure that individuals with disabilities and elderly adults are able to live in integrated settings without delayed access to needed services.
- To provide medical assistance for those whose income is insufficient to meet the costs of care.
- To ensure that individuals with disabilities have the capability to remain independent and receive services that enable them to continue living in their communities.
- To update access to services by eliminating the need for states to apply for waivers thereby increasing the services that are available to those in need.
It has been acknowledged that the bill needs work, and NAHC, among others, has offered comments which we summarize below. NAHC has suggested that:
- The bill should establish national standards for the minimum scope and duration of services that would be offered under the benefit. Because all the financing would come from the federal government, it should have the ability to establish minimum standards that would apply to all states.
- Standards should also be established to govern rate setting and payment methodologies to ensure “care access and supports for frontline caregivers.” This would be designed to ensure a living wage for caregivers and staff providing covered services.
- The program must recognize the wide differences in the patient populations served and should include full access for self-directed care models as well as agency services.
- NAHC suggests that it “might be useful to consider steps that would make health insurance affordable through the ACA marketplace” or other action that would make lower barriers to Medicaid eligibility.
- Given the dual eligibility status of many recipients of home- and community-based services through a waivered plan, it will be useful to establish directives as to how the HCBS services would relate to other available Medicaid benefits.
NAHC’s recommendations go on to suggest inclusion of palliative care benefits as well as meals and nutritional support. The bill is a long way from its final conclusion, but definitely worth watching, especially for those agencies that provide home- and community-based services to a portion of their clients.
Compliance
Available tax credits for COVID-19 employee leave
The Internal Revenue Service (IRS) has instituted provisions, under the American Rescue Plan Act of 2021 (ARP Act), that will allow certain types of employers to claim refundable tax credits to offset the cost of providing paid sick and/or family leave to employees due to COVID-19. This will include paid time off for receiving and/or recovering from the aftereffects of a COVID-19 vaccination. The information we’ve included below can also be found here. There are several things readers should know about the ARP Act provisions:
- “Eligible employer” definition: Eligible employers are defined as those with fewer than 500 employees and self-employed individuals. Eligible employers are entitled to tax credits for wages paid for leave taken by employees who are not able to work or telecommute due to reasons related to COVID-19. This includes time taken and leave provided for COVID-19 vaccinations or to recover from illness or injury related to the vaccination.
- Time period for claiming the credits: The time period for available tax credits is from April 1, 2021 through September 30, 2021.
- Calculation of the credit: The tax credits go against the employer’s share of the Medicare tax and they are refundable, which means that the employer is entitled to receive the full amount of the credits that exceed the employer share of the Medicare tax. According to the IRS, “the tax credit for paid sick leave wages is equal to the sick leave wages paid for COVID-19 related reasons for up to two weeks (80 hours), limited to $511 per day and $5,110 in the aggregate, at 100 percent of the employee’s regular rate of pay.”
“The tax credit for paid family leave wages is equal to the family leave wages paid for up to twelve weeks, limited to $200 per day and $12,000 in the aggregate, at two-thirds of the employee’s regular rate of pay. The amount of these tax credits is increased by allocable health plan expenses and contributions for certain collectively bargained benefits, as well as the employer’s share of social security and Medicare taxes paid on the wages (up to the respective daily and total caps).” - Claiming the credit: Eligible employers may claim tax credits for sick and family leave paid to employees, including leave taken to receive or recover from COVID-19 vaccinations from April 1, 2021 through September 30, 2021.Eligible employers will report their total paid sick and family leave wages (plus the eligible health plan expenses and collectively bargained contributions and the eligible employer’s share of social security and Medicare taxes on the paid leave wages) for each quarter on their federal employment tax return, usually Form 941 which is the Employer’s Quarterly Federal Tax Return. In anticipation of claiming the credits on Form 941, eligible employers can keep the federal employment taxes that they otherwise would have deposited, including federal income tax withheld from employees, the employees’ share of social security and Medicare taxes, and the eligible employer’s share of social security and Medicare taxes with respect to all employees up to the amount of credit for which they are eligible. The instructions for Form 941 explain how to reflect the reduced liabilities for the quarter related to the deposit schedule.If an eligible employer does not have enough federal employment taxes set aside for deposit to cover amounts provided as paid sick and family leave wages (plus the eligible health plan expenses and collectively bargained contributions and the eligible employer’s share of social security and Medicare taxes on the paid leave wages), the eligible employer may request an advance of the credits by filing Form 7200, Advance Payment of Employer Credits Due to COVID-19. The eligible employer will account for the amounts received as an advance when it files its Form 941 for the relevant quarter.Self-employed individuals may claim comparable tax credits on their individual Form 1040.
Clinical
New guidelines from the CDC for vaccinated individuals
Last week, on April 27, the CDC came out with new health and safety guidelines for those who have been fully vaccinated against COVID-19. The good news is that the CDC has now opined that many activities that were previously not recommended are now considered safe for vaccinated people. Here is what you need to know:
- Guiding principles for fully vaccinated people are now provided.
- The guidance underscores that immunocompromised people need to consult their healthcare provider about these recommendations, even if fully vaccinated.
- Fully vaccinated people no longer need to wear a mask outdoors, except in certain crowded settings and venues.
- Fully vaccinated workers no longer need to be restricted from work following an exposure as long as they are asymptomatic.
- Fully vaccinated residents of non-healthcare congregate settings no longer need to quarantine following a known exposure.
- Fully vaccinated asymptomatic people without an exposure may be exempted from routine screening testing, if feasible.
- The recommendations for fully vaccinated people will be updated based on the level of community spread of the virus compared to the proportion of the population that is fully vaccinated.
For the purposes of this guidance, people are considered fully vaccinated for COVID-19 two weeks after they have received the second dose in a two-dose series (Pfizer-BioNTech or Moderna), or two weeks after they have received a single-dose vaccine (Johnson and Johnson/Janssen).
This guidance applies to COVID-19 vaccines currently authorized for emergency use by the U.S. Food and Drug Administration (FDA): Pfizer-BioNTech, Moderna, and Johnson and Johnson/Janssen COVID-19 vaccines. This guidance can also be applied to COVID-19 vaccines that have been authorized for emergency use by the World Health Organization (e.g. AstraZeneca/Oxford).
The following guidance applies to all healthcare staff and all patients or residents while they are being cared for in a healthcare setting:
At this time, there is limited data on vaccine protection in people who are immunocompromised. Further, data on which immunocompromising conditions might affect response to the COVID-19 vaccine and the magnitude of risk are not available. Examples of such immunocompromising conditions likely include, but might not be limited to, receiving chemotherapy for cancer, hematologic malignancies, being within one year from receiving a hematopoietic stem cell or solid organ transplant, untreated HIV infection with CD4 T lymphocyte count < 200, combined primary immunodeficiency disorder, and taking immunosuppressive medications (e.g., drugs to suppress rejection of transplanted organs or to treat rheumatologic conditions such as mycophenolate and rituximab, receipt of prednisone >20mg/day for more than 14 days). In general, healthcare facilities should continue to follow the infection prevention and control recommendations for unvaccinated individuals (e.g., quarantine, testing) when caring for fully vaccinated individuals with an immunocompromising condition.
Except as noted in the updated recommendations below, healthcare staff should continue to follow all current infection prevention and control recommendations, including those addressing work restrictions, quarantine, testing, and use of personal protective equipment to protect themselves and others from SARS-CoV-2 infection. Below are key points from the CDC recommendations for healthcare staff and patients/residents in post-acute facilities.
Visitation:
Indoor visitation could be permitted for all residents in post-acute care facilities, including nursing homes, except as noted below:
- Indoor visitation for unvaccinated residents should be limited solely to compassionate care situations if the COVID-19 county positivity rate is greater than 10% and fewer than 70% of residents in the facility are fully vaccinated.
- Indoor visitation should be limited solely to compassionate care situations, for:
- Vaccinated and unvaccinated residents with SARS-CoV-2 infection until they have met criteria to discontinue transmission-based precautions.
- Vaccinated and unvaccinated residents in quarantine until they have met criteria for release from quarantine.
- Facilities in outbreak status should follow guidance from state and local health authorities and CMS on when visitation should be paused.
- Visitors should be counseled about their potential to be exposed to SARS-CoV-2 in the facility if they are permitted to visit.
- Additional information is available in the CMS memo addressing nursing home visitation – COVID-19 (Revised 3/10/2021) and the CMS memo addressing visitation at intermediate care facilities for individuals with intellectual disabilities and psychiatric residential treatment facilities
Recommended infection prevention and control practices when planning for and allowing visitation in post-acute and acute care facilities:
- Facilities should continue to promote and provide vaccination for all healthcare professionals.
- Post-acute care facilities should continue to encourage vaccination among all new admissions.
- Facilities should maintain a record of the vaccination status of patients/residents and healthcare professionals.
- Before allowing indoor visitation, the risks associated with visitation should be explained to patients/residents and their visitors so they can make an informed decision about participation.
- Full vaccination for visitors is always preferred, when possible.
- Visitors should be screened and restricted from visiting, regardless of their vaccination status, if they have: current SARS-CoV-2 infection; symptoms of COVID-19; or prolonged close contact (within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period) with someone with SARS-CoV-2 infection in the prior 14 days or have otherwise met criteria for quarantine.
- Visitors should be counseled about recommended infection prevention and control practices that should be used during the visit (e.g., facility policies for source control or physical distancing).
- Visitors, regardless of their vaccination status, should wear a well-fitting cloth mask, facemask, or respirator (N95 or a respirator approved under standards used in other countries that are similar to NIOSH-approved N95 filtering facepiece respirators) for source control, except as described in the scenarios below.
- Hand hygiene should be performed by the patient/resident and the visitors before and after contact.
- High-touch surfaces in visitation areas should be frequently cleaned and disinfected.
- Facilities should have a plan to manage visitation and visitor flow.
- Visitors, regardless of their vaccination status, should physically distance (maintaining at least 6 feet between people) from other patients/residents, visitors that are not part of their group, and healthcare professionals in the facility, except as described in the scenarios below.
- Facilities might need to limit the total number of visitors in the facility at one time in order to maintain recommended infection control precautions. Facilities might also need to limit the number of visitors per patient/resident at one time to maintain any required physical distancing.
- Location of visitation if occurring indoors:
- If the patient/resident is in a single-person room, visitation could occur in their room.
- Visits for patients/residents who share a room should ideally not be conducted in the patient/resident’s room.
- If in-room visitation must occur (e.g., patient/resident is unable to leave the room), an unvaccinated roommate should not be present during the visit. If neither patient/resident is able to leave the room, facilities should attempt to enable in-room visitation while maintaining recommended infection prevention and control practices, including physical distancing and source control.
- If visitation is occurring in a designated area in the facility, facilities could consider scheduling visits so that multiple visits are not occurring simultaneously, to the extent possible. If simultaneous visits do occur, everyone in the designated area should wear source control and physical distancing should be maintained between different visitation groups regardless of vaccination status.
Physical distancing and source control recommendations when both the patient/resident and all of their visitors are fully vaccinated:
- While alone in the patient/resident’s room or the designated visitation room, patients/residents and their visitor(s) can choose to have close contact (including touch) and to not wear source control.
- Visitors should wear source control and physically distance from other healthcare personnel and other patients/residents/visitors that are not part of their group at all other times while in the facility.
Physical distancing and source control recommendations when either the patient/resident or any of their visitors are not fully vaccinated:
- The safest approach is for everyone to maintain physical distancing and to wear source control. However, if the patient/resident is fully vaccinated, they can choose to have close contact (including touch) with their unvaccinated visitor(s) while both continue to wear well-fitting source control.
Healthcare personnel:
- In general, fully vaccinated healthcare staff should continue to wear source control while at work. However, fully vaccinated healthcare staff could dine and socialize together in break rooms and conduct in-person meetings without source control or physical distancing. If unvaccinated staff members are present, everyone should wear source control, and unvaccinated staff members should physically distance from others.
The actual CDC articles are longer and worth the read. Only portions have been included above, but the full articles are linked throughout.
Administrative
COVID-19 vaccine and monoclonal antibody billing
Recently, Palmetto GBA released information regarding billing for COVID-19 vaccines and monoclonal antibodies. This information pertains to all three of the home health and hospice Medicare Administrative Contractors (MACs) including NGS and CGS.
Here is the information that home health and hospice providers need to know.
To bill single claims for COVID-19 vaccines and monoclonal antibodies, follow the instructions below:
- For roster billing and centralized billing, reference the Medicare billing for COVID-19 vaccine shot administration page
- When COVID-19 vaccine and monoclonal antibody doses are provided by the government without charge, only bill for the vaccine administration. Don’t include the vaccine codes on the claim when the vaccines are provided free of charge.
- If the patient is enrolled in a Medicare Advantage (MA) plan, submit your COVID-19 vaccine and monoclonal antibody infusion claims to Original Medicare in 2020 and 2021.
Type of bill (TOB): The TOB codes to report for the COVID-19 vaccine and monoclonal antibody infusion on the home health and hospice claim form, or electronic equivalent, are:
- 341 – Home Health Outpatient (Part B)
- 81X – Hospice (non-hospital based)
- 82X – Hospice (hospital based)
COVID-19 vaccines and administration
Revenue codes:
- 0771 — Preventive care services, vaccine administration. Per CMS, although there are more accurate revenue codes available for reporting of the infusions, the current guidance is for providers to utilize Revenue Code 0771 to report the infusion until further instruction is issued.
- 0636 — Pharmacy, drugs requiring detailed coding
Current Procedural Terminology (CPT): COVID-19 vaccines and administration codes are under Payment Allowances and Effective Dates for COVID-19 Vaccines and their Administration During the Public Health Emergency.
*Providers should not bill for the product if they received it for free.
Condition codes:
- A6 — 100 percent payment
- 78 — New coverage not implemented by Medicare Advantage (billed on claims for Medicare Advantage beneficiaries only)
Diagnosis codes:
- Z23 — Encounter for immunization. Per CMS, this code must be included when reporting an encounter for the COVID-19 vaccine or monoclonal antibody treatment.
- U071 — COVID-19
Monoclonal antibodies and administration
Revenue codes:
- 0771 — Preventive care services, vaccine administration. Per CMS, although there are more accurate revenue codes available for reporting of the infusions, the current guidance is for providers to utilize this code to report the infusion until further instruction is issued.
- 0636 — Pharmacy, drugs requiring detailed coding
Monoclonal antibodies and administration codes are under Payment Allowances and Effective Dates for COVID-19 Monoclonal Antibodies and their Administration during the Public Health Emergency.
*Providers should not bill for the product if they received it for free.
Condition codes:
- A6 — 100 percent payment. Per CMS, Modifier CS is not required to be reported when billing instructions are utilized, as the Part A systems have been updated to ensure there is no cost share for the patient for COVID-19 vaccines or monoclonal antibody treatments. Please note: The drug should be reported with Revenue Code 0636, and the administration/infusion should be reported with Revenue Code 0771.
- 78 — New coverage not implemented by Medicare Advantage (billed on claims for Medicare Advantage beneficiaries only)
Diagnosis codes:
- Z23 — Encounter for immunization. Per CMS, this code must be included when reporting an encounter for the COVID-19 vaccine or monoclonal antibody treatment.
- U071 — COVID-19
CMS will exercise such discretion:
- During the emergency period defined in paragraph (1)(B) of section 1135(g) of the Social Security Act (42 U.S.C. § 1320b-5(g)) and ending on the last day of the calendar quarter in which the last day of such emergency period occurs; or
- So long as CMS determines that there is a public health need for mass COVID-19 vaccinations in congregate care settings, whichever is later.
In closing
This month I found a story I couldn’t resist sharing about Buffy the yellow Lab who is able to sniff out COVID-19 and is “working” at Doctors Hospital in Sarasota. When on the job, Buffy will lay down at the feet of a visitor detected with COVID-19 “smells” as she passes by. Buffy didn’t come by this rare talent naturally – she was trained – and while the hospital hasn’t scuttled its more traditional technologic approaches to COVID-19 testing, Buffy’s services are offered to visitors who can also avail themselves of onsite testing or leave the facility to get tested somewhere else if Buffy detects the presence of the virus. Buffy can do her work in mere seconds – much more quickly than the time required for an average COVID-19 test – and she works for treats. Not to mention, who wouldn’t want to meet Buffy on the way into the hospital? As an added benefit, Buffy lives with Robert Meade, the hospital’s CEO so I’m guessing she gets a free ride to work each day. You can see Buffy at work here.
As always, thanks for all that you do – stay safe, get your vaccination if you haven’t already, and take things one day at a time. I’ll be back next month with more.