Sweeping CMS Waivers Give Flexibility to Nephrologists during COVID-19 Crisis

By David White

April 1, 2020

After much urging from the American Society of Nephrology (ASN) and other members of the kidney community, the Centers for Medicare and Medicaid Services (CMS) issued a sweeping interim final rule on March 30 that provides multiple waivers the community requested to provide greater flexibility during the COVID-19 public health emergency (PHE). Of particular importance for ASN members, the rule greatly expands the use of telehealth in providing care to kidney patients – especially those with kidney failure receiving dialysis – for the duration of the PHE. CMS clarified that all evaluations of dialysis patients covered under the ESRD monthly capitated payment (MCP) may now be conducted via telehealth to protect those vulnerable patients and prevent further spread of the novel coronavirus 2019.

Specifically, all monthly MCP evaluations of in-center and home dialysis patients are approved for telehealth provided the clinician deems those patients to be in stable condition. Under the current waivers, telephonic communications and the use of non-HIPPA complaint platforms like Skype are also permitted. Additionally, the CPT codes for audio-only telephone E&M services (CPT codes 99441-99443) are now covered and Medicare will reimburse physicians for those phone calls with their patients.

CMS also expanded the Special Purpose Renal Dialysis Facilities (SPRDF) designation. CMS writes “CMS authorizes the establishment of SPRDFs to address access to care issues due to COVID-19 and the need to mitigate transmission among this vulnerable population.” This move is designed to provide latitude for dialysis facilities to provide services in different locations – such as a facility specifically for those with COVID-19 or those who are asymptomatic with the 2019 novel coronavirus.

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Author:
David White
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After much urging from the American Society of Nephrology (ASN) and other members of the kidney community, the Centers for Medicare and Medicaid Services (CMS) issued a sweeping interim final rule on March 30 that provides multiple waivers the community requested to provide greater flexibility during the COVID-19 public health emergency (PHE). Of particular importance for ASN members, the rule greatly expands the use of telehealth in providing care to kidney patients – especially those with kidney failure receiving dialysis – for the duration of the PHE. CMS clarified that all evaluations of dialysis patients covered under the ESRD monthly capitated payment (MCP) may now be conducted via telehealth to protect those vulnerable patients and prevent further spread of the novel coronavirus 2019.

Specifically, all monthly MCP evaluations of in-center and home dialysis patients are approved for telehealth provided the clinician deems those patients to be in stable condition. Under the current waivers, telephonic communications and the use of non-HIPPA complaint platforms like Skype are also permitted. Additionally, the CPT codes for audio-only telephone E&M services (CPT codes 99441-99443) are now covered and Medicare will reimburse physicians for those phone calls with their patients.

CMS also expanded the Special Purpose Renal Dialysis Facilities (SPRDF) designation. CMS writes “CMS authorizes the establishment of SPRDFs to address access to care issues due to COVID-19 and the need to mitigate transmission among this vulnerable population.” This move is designed to provide latitude for dialysis facilities to provide services in different locations – such as a facility specifically for those with COVID-19 or those who are asymptomatic with the 2019 novel coronavirus.

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Wednesday, April 1, 2020