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COVID-19 Guide for Patients and Providers

Summary

As our healthcare industry rapidly evolves to address the COVID-19 pandemic, keep track of new resources and policies affecting patients and providers with the COVID-19 guide below.

Last updated June 22, 2020.

Topics

Patient Affordability
Topic Description Timelines Source(s) of Authority Resources
Cost Sharing for COVID-19 Testing Medicaid/Medicare: New cost-sharing requirements for COVID-19 testing have been established for Medicare, MA, and Medicaid. Lasts for duration of the national public health emergency Family First Coronavirus Response Act CMS FAQs for state Medicaid agencies on FFCRA and the CARES Act
Commercial: New cost-sharing requirements for COVID-19 testing have been established for commercial health plans. Lasts for the duration of the national public health emergency Family First Coronavirus Response Act AHIP list of commercial insurers’ COVID-19 policies
CMS FAQs on commercial coverage of testing
Uninsured: Funds have been set aside by Congress for testing the uninsured. Some states may cover testing for the uninsured under their Medicaid programs. N/A Paycheck Protection Program and Healthcare Enhancement Act
Family First Coronavirus Response Act
CMS FAQs for state Medicaid agencies on FFCRA and the CARES Act HRSA guide for COVID-19 testing and treatment for the uninsured
Cost Sharing for COVID-19 Treatment Medicare: Patients in traditional Medicare may be subject to standard Medicare cost sharing, including any supplemental coverage, for treatment. New cost-sharing requirements and flexibilities have been established for MA
plans.
Changes to MA requirements last for duration of the national public health emergency CMS Memo to MAOs and Part D Sponsors Medicare cost sharing at a glance
CMS overview of Medicare and COVID-19
KFF FAQs on Medicare coverage and costs related to COVID-19
Medicaid: New cost-sharing requirements have been established for states who accept increased federal matching funds under the Family First Coronavirus Response Act. Lasts for duration of the national public health emergency Family First Coronavirus Response Act CMS FAQs for Medicaid Agencies on FFCRA
Coverage and benefits for COVID-19 related to Medicaid and CHIP
Commercial: Some private insurers have committed to altering cost sharing for COVID-19 treatment. Additionally, some states have established commercial plan requirements for cost sharing. N/A Commercial payer discretion and state authority AHIP list of commercial insurers’ COVID-19 policies
KFF overview of state COVID-19 policy actions
Cost Sharing for Telehealth Services Medicare: New flexibilities have been given to Medicare providers to alter cost-sharing obligations for telehealth services in federal healthcare programs. Additional cost-sharing flexibilities have been provided to MA plans. Lasts for duration of the national public health emergency First Interim Final Rule: Response to the COVID-19 Public Health Emergency
OIG Ruling on Cost Sharing for Telehealth Services
CMS Memo to MAOs and Part D Sponsors
Medicare coverage of telehealth
KFF FAQs on Medicare coverage and costs related to COVID-19
Medicaid: Some states have altered cost-sharing requirements and changed Medicaid coverage for telehealth services. Varies; most changes end with the duration of the national public health emergency and/or state-declared emergencies State Plan Amendments
State Executive Orders
State Medicaid telehealth toolkit
CMS FAQs for state Medicaid agencies on FFCRA and the CARES Act
Commercial: Some state executive orders have established new cost sharing requirements for commercial health plans. Additionally, some private insurers have announced that they are independently altering cost sharing standards for telehealth services. Varies; most changes end with the duration of the national public health emergency or state-declared emergencies State Executive Orders AHIP list of commercial insurers’ COVID-19 policies
APTA summary of state actions related to telehealth
Forbes list of state actions
Premium Payment Flexibilities Medicaid: Several states have been approved for state plan amendments that change premium and enrollment fee requirements for Medicaid beneficiaries. Lasts for the duration of the national public health emergency State Plan Amendments KFF overview of state COVID-19 policy actions
Commercial: New flexibilities have been established for marketplace exchange plans to alter premium payment deadlines. Some state executive orders have made changes to premium payment policies for commercial health plans. Lasts for the duration of the national public health emergency CMS Guidance to Plans on the Federally-Facilitated or State-based Exchanges KFF overview of state COVID-19 policy actions

Care Delivery
Topic Description Timelines Source(s) of Authority Resources
Telehealth Flexibilities Medicare: New policies have been established that change traditional Medicare coverage for telehealth services and create additional provider flexibilities. MA plans have been encouraged to change existing telehealth
requirements.
Lasts for the duration of the national public health emergency; some changes likely to be made permanent First Interim Final Rule: Response to the COVID-19 Public Health Emergency
Coronavirus Preparedness and Response Supplemental Appropriations Act
CMS Memo to MAOs and Part D Sponsors
Second Interim Final Rule: Response to the COVID-19 Public Health Emergency
KFF FAQs on Medicare coverage and costs related to COVID-19
Medicare telemedicine provider fact sheet
Business Group on Health’s strategies for expanding telemedicine
Medicaid: Telehealth policies vary across state Medicaid agencies. Some states have changed policies related to telehealth coverage and flexibilities. Varies by state State Medicaid programs State Medicaid telehealth toolkit
CCHPCA list of COVID-19 state telehealth actions
Commercial: Some commercial payers have expanded telehealth coverage policies. Varies by payer Commercial payer discretion AHIP list of commercial insurers’ COVID-19 policies
Home Health Flexibilities Medicare: New flexibilities have been established to expand coverage under the Medicare Home Health Benefit and relax certain requirements for providers and home health agency staff to administer services in the home setting. The duration of the public health emergency First Interim Final Rule: Response to the COVID-19 Public Health Emergency
Second Interim Final Rule: Response to the COVID-19 Public Health Emergency
CMS home health agency guidance
Medicaid: A subset of states have submitted waivers to modify home health requirements and expand coverage for services. Varies by state Section 1915(c) waivers COVID-19 frequently asked questions for state Medicaid agencies
Home Infusion Flexibilities Medicare: Providers and home health agencies have been granted new flexibilities to administer drugs in the home setting. The duration of the public health emergency First Interim Final Rule: Response to the COVID-19 Public Health Emergency CMS COVID-19 provider guide
FDA home infusion pump guidance

Provider Reimbursement
Topic Description Timelines Source(s) of Authority Resources
Reimbursement for COVID-19 Testing Medicare: Medicare Administrative Contractors (MACs) have established reimbursement rates for high-throughput COVID-19 testing methods, the CDC-developed test, and other COVID-tests. The CMS has created new flexibilities related to Medicare and MA provider payment for COVID-19 testing. Permanent CMS Ruling on COVID-19 Testing Reimbursement
Second Interim Final Rule: Response to the COVID-19 Public Health Emergency
CMS’s Medicare provider FAQ
MAC COVID-19 test pricing chart
Commercial: Specific provider reimbursement standards for COVID-19 testing have been established for commercial plans. Permanent CARES Act CMS FAQs on commercial coverage of testing
Uninsured: A special reimbursement process has been established, based on Medicare payment rates, for providers who have conducted COVID-19 testing for uninsured patients. Providers that submit claims can begin receiving reimbursement in mid-May CARES Act
Family First Coronavirus Response Act
HRSA guide for COVID-19 testing and treatment for the uninsured
Reimbursement for COVID-19 Treatment Medicare/Medicaid/Commercial: Standard provider reimbursement for outpatient and inpatient services generally applies to COVID-19 treatment. The CMS has changed payment rules related to services provided in non-traditional settings and high-capacity healthcare facilities. Permanent Second Interim Final Rule: Response to the COVID-19 Public Health Emergency CMS coverage and payment related to COVID-19 Medicare
ASCO overview of COVID-19 government, reimbursement and regulatory updates
Uninsured: A special reimbursement process has been established, based on Medicare payment rates, for providers who have conducted COVID-19 testing for uninsured patients. Providers that submit claims can begin receiving reimbursement in mid-May CARES Act
Family First Coronavirus Response Act
HRSA guide for COVID-19 testing and treatment for the uninsured
Accelerated and Advanced Medicare Payments Medicare: The CMS has made changes to the Accelerated and Advance Medicare Payment Program for Part A and Part B providers. Lasts for the duration of the national public health emergency CARES Act
CMS Announcementannouncement on Suspending the Accelerated and Advanced Payment Program
CMS fact sheet on accelerated and advanced payments
Reimbursement for Telehealth Medicare: New regulations have changed provider reimbursement for telehealth visits, allowed new provider flexibilities, altered hospital billing for telehealth services, and established new telehealth CPT codes. Lasts for the duration of the national public health emergency; some likely to be made permanent. First Interim Final Rule: Response to the COVID-19 Public Health Emergency
Coronavirus Preparedness and Response Supplemental Appropriations Act
Second Interim Final Rule: Response to the COVID-19 Public Health Emergency
Medicare telemedicine provider fact sheet
Business Group on Health’s strategies for expanding telemedicine
Medicaid: Telehealth reimbursement policies vary from state to state. Some state Medicaid programs have changed coverage and reimbursement for telehealth services. Varies by state State Medicaid Programs State Medicaid telehealth toolkit
CMS bulletin on Medicaid telehealth
Commercial: Reimbursement for telehealth services varies by commercial payer. Some commercial payers have changed telehealth coverage requirements and/or adjusted provider reimbursement rates. Varies by payer Commercial Payer Discretion AHIP list of commercial insurers’ COVID-19 policies
Provider Relief Funding General relief funding has been allotted for Medicare providers and facilities, hospitals in high impact areas, rural providers, and other healthcare entities impacted by COVID-19. N/A CARES Act
Paycheck Protection Program and Healthcare Enhancement Act
Distribution of CARES Act Provider Relief Fund

Provider Relief Fund terms and conditions
HHS update on distribution of payments

HHS update on timeline for additional payments from Provider Relief Fund

Compliance deadline extension for providers

HHS announcement on funding for Medicaid providers and safety net hospitals

Balance Billing Certain requirements related to limiting balance billing for COVID-19 services have been established for providers who accept money from the CARES Act’s Provider Relief Fund. N/A Provider Relief Fund Terms and Conditions Distribution of CARES Act Provider Relief Fund

Utilization Management
Topic Description Timelines Source(s) of Authority Resources
Prior Authorization for COVID-19 Testing Medicare/Medicaid/Commercial: Requirements related to prior authorization have been established for payers’ coverage of COVID-19 testing. Lasts for the duration of the national public health emergency Family First Coronavirus Response Act CMS FAQs on commercial coverage of testing
Prior Authorization for Prescription Drugs Medicare: The CMS has provided guidance to Part D sponsors and Medicare Advantage (MA) organizations on altering prior authorization for prescription drugs. Permanent CMS Memo to MAOs and Part D Sponsors ASCO overview of COVID-19 government, reimbursement and regulatory updates
Medicaid: Many states have temporarily changed Medicaid prior authorization requirements for prescription drugs. Varies; most changes end with the duration of the national public health emergency and/or state-declared emergencies 1135 Waiver Amendments
Approved State Plan Amendments
KFF overview of state COVID-19 policy actions
Commercial: Some health plans have extended existing prior authorizations for prescription drugs or adopted additional utilization management flexibilities. Varies by payer Commercial payer discretion AMA prior authorization policy changes related to COVID-19

Other
Topic Description Timelines Source(s) of Authority Resources
Provider Liability New liability protections have been established for health professionals who provide services during the COVID-19 emergency. Lasts for the duration of the national public health emergency CARES Act AMA overview of liability protections during COVID-19
CMS announcement on new reporting guidelines
Provider Practicing Flexibilities New flexibilities have been granted to allow some healthcare professionals to practice outside their normal operations, and to change requirements related to the direct supervision of procedures. The CMS has also relaxed facility requirements
to allow increased hospital capacity and enable the provision of healthcare services in certain non-traditional medical facilities. Additionally, many states have changed out-of-state licensing requirements for providers.
Lasts for the duration of the national public health emergency First Interim Final Rule: Response to the COVID-19 Public Health Emergency
CMS Guidance on Maximizing Frontline Healthcare Workforce
Second Interim Final Rule: Response to the COVID-19 Public Health Emergency
CMS physician and clinician flexibilities
Quality Reporting Medicare: CMS has changed reporting requirement timelines and financial methodologies for CMS Innovation Center (CMMI) models and for multiple quality measure and value-based purchasing programs, including the Medicare Shared Savings Program. Varies by CMS program CMS Memo: HHS Postponement of HHS-RADV
First Interim Final Rule: Response to the COVID-19 Public Health Emergency
CMS Announcement on New Reporting Guidelines
Second Interim Final Rule: Response to the COVID-19 Public Health EmergencyCMS Announcement on Adjustments to CMMI Models
AMA overview of liability protections during COVID-19
Prescription Drug Access Flexibilities Medicare: New requirements have been established related to Part D sponsors’ refill and drug supply policies. Additional permissions have been granted to support mail or home delivery for retail pharmacies. Lasts for the duration of the national public health emergency CARES Act
CMS Memo to MAOs and Part D Sponsors
CMS PDP and MA-PD COVID-19 flexibilities
Clinical Trials The FDA has provided guidance on conducting clinical trials during the pandemic to help sponsors determine when shifts to alternative settings or trial discontinuation may be appropriate. The Coronavirus Treatment Acceleration Program (CTAP) has been established to expedite the development of safe and effective treatments for COVID-19. Lasts for the duration of the national public health emergency FDA Guidance on Conducting Clinical Trials on Medical Products During Pandemic CTAP NIH’s Clinicaltrials.gov
Non-Essential Surgeries and Procedures The CMS has released guidance on conducting non-essential procedures and on the operating status of healthcare facilities during the pandemic. States have the ultimate authority to decide whether to resume elective procedures. Dependent on individual state reopening plans CMS Non-Emergent, Elective Medical Services and Treatment Recommendations
CMS Recommendation for Re-opening Facilities
ASCA overview of state guidance on elective surgeries

Additional Resources

Additional Resources for Telehealth

Resources Specific to Therapeutic Area

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