Following the outbreak of the COVID-19 pandemic in the U.S. a month ago, the Centers for Medicare & Medicaid Services (CMS) issued an array of temporary regulatory waivers and new rules to provide the nation’s healthcare system with maximum flexibility to deal with this public health emergency. Our medical billing company reported on these developments, including updated guidelines for reporting telemedicine services.

On March 18, the Centers for Medicare & Medicaid Services (CMS) announced measures to augment services for patients with COVID-19 by “limiting non-essential care and expanding surge capacity into ambulatory surgical centres and other areas”. The goal was to preserve resources such as personal protective equipment, beds, and ventilators as well as to free up healthcare workforce to care for patients exposed to the virus. The limits on non-essential care put a hold on elective surgeries and non-essential medical, surgical, and dental procedures.

Recommendations for Restarting Non-Emergent Procedures

With the federal government’s call for Opening Up America Again, CMS announced plans for restarting non-emergent care. In a statement issued on April 19, CMS noted that “at this time many areas have a low, or relatively low and stable incidence of COVID-19, and that it is important to be flexible and allow facilities to provide care for patients needing non-emergent, non-COVID-19 healthcare”. CMS plans to restart certain procedural care (surgeries and procedures), chronic disease care, and, finally, preventive care, all of which had been postponed due to COVID-19.

CMS recommends resuming in-person care of non-COVID-19 patients in regions with low incidence of COVID-19 disease. With the surge in COVID-19 cases, CMS updated policies for telehealth to create a mechanism for patients to stay at home and communicate with physicians on the status of their health, while protecting healthcare workers and the community at large. While encouraging maximum use of telehealth modalities, CMS now recommends that healthcare systems and facilities offer non-COVID-19 care as clinically appropriate and within a state, locality, or facility “that has the resources to provide such care and the ability to quickly respond to a surge in COVID-19 cases, if necessary”. These decisions, notes CMS, should “be consistent with public health information and in collaboration with state public health authorities”.

The recommendations also outline the general considerations for providing clinically necessary care for patients with non COVID-19 needs or complex chronic disease management requirements, personal protective equipment (PPE), workforce availability, facility considerations, sanitation protocols, supplies and testing capacity.

General Considerations:

  • Coordinating with State and local public health officials to evaluate COVID-19 incidence and trends in the area where restarting of in-person care is being considered.
  • Providers should evaluate the necessity of the care, prioritize surgical/procedural care and high-complexity chronic disease management, and select preventive services as necessary.
  • Consider establishing Non-COVID Care (NCC) zones to screen all patients for COVID-19 symptoms, including temperature checks. Staff, physicians, nurses, housekeeping, delivery and all people who enter the area should be routinely screened.
  • Resources such as PPE, healthy workforce, facilities, supplies, testing capacity, and post-acute care should be available to the facility across phases of care, without jeopardizing surge capacity.

Personal Protective Equipment

  • Healthcare providers and staff should wear surgical facemasks at all times. Appropriate respiratory protection should be utilized while performing procedures on the mucous membranes and respiratory tract.
  • Patients should wear a cloth face covering/surgical mask.
  • Careful conservation of PPE.

Workforce Availability

  • Routine screening of staff for COVID -19 symptoms and testing and quarantining of symptomatic persons.
  • Staff in NCC zones should be limited to working in these areas and not rotate into “COVID-19 Care zones”.
  • Adequate staffing levels in the community to cover a potential surge in COVID-19 cases.

Facility Considerations and Testing

  • All patients must be screened for potential symptoms of COVID-19 prior to entering the NCC facility and staff must be routinely screened for potential symptoms.
  • Patients should be screened by laboratory testing before care, and laboratory testing should be used to screen staff as well.
  • Facilities in regions with low incidence rate that decide to provide in-person non-emergent care should create separate areas of NCC as well as measures to reduce risk of COVID-19 exposure and transmission. These areas should be separate from other facilities to the degrees possible (i.e., “separate building, or designated rooms or floor with a separate entrance and minimal crossover with COVID-19 areas”).
  • Controls should be established within the facility to allow for social distancing.
  • Visitors should be prohibited, but if they are allowed, be pre-screened similar to patients.

Sanitation and Supplies

  • Facilities should have an established plan for thorough cleaning, disinfection prior to using spaces or facilities for patients with non-COVID-19 care needs. CDC guidelines should be followed when decontaminating equipment used for COVID-19 patients.
  • Adequate supplies of equipment, medication and supplies must be ensured.

Moving Forward

CMS’ plans to reopen non-emergent care will allow many procedures labeled “non-essential” or “elective” to take place. However, a Medpage article published on May 4 observes that many of these procedures that were put on hold due to the pandemic are actually critical for the health and well-being of many patients. Examples of conditions for which delayed treatment can cause severe complications include uterine fibroids with heavy bleeding and pain, severe foot pain that develops complications, and open wounds due to peripheral arterial disease. The report notes that procedures for these conditions may seem elective, but they are truly vital.

The way forward, according to the article is to improve emergency preparedness in order to maintain the vital healthcare treatments that take place outside of hospitals. This can be done by:

  • Providing a clear universal definition of “essential procedures”
  • Expanding the definition of “essential” care, based on local infection rates and healthcare capacity
  • Resuming customary treatments without jeopardizing the COVID response or endangering other patients’ health. The article recommends going by the Roadmap for Resuming Elective Surgery developed by the American College of Surgeons in conjunction with leading other associations.
  • Ensuring that (resource-rich) private practice and outpatient care settings are included in emergency preparedness plans.

As facilities to provide elective surgeries, non-essential medical, surgical, and dental procedures are reopened, the support of an experienced medical billing service provider would be invaluable to prepare and submit claims for appropriate reimbursement.