PHE: The Beginning of the End

The federal Public Health Emergency (PHE) ends on May 11, but please be aware that everything does not stop on May 11. For example, the New COVID-19 Treatment Add-On Payment (NC-TAP) will continue until Sept. 30, which is the end of the fiscal year in which the PHE will end. The Medicare enhanced payment will continue for:

1. Convalescent plasma;
2. VEKLURY® (remdesivir);
3. Olumiant ® (baricitinib);
4. Molnupiravir;
5. Paxlovid ™ (nirmatrelvir packaged with ritonavir); and
6. Kineret ® (anakinra).

To continue to receive NCTAP, which is a 20-percent add-on payment, assign U07.1 (COVID-19) and the ICD-10-PCS codes for remdesivir, convalescent plasma, or baricitinib. If using Paxlovid or molnupiravir, then submit the National Drug Codes (NDCs). See the CMS COVID-19 Toolkit for the detailed procedure codes for NDCs.

As we prepare for the end of the PHE, it is important to have discussions with other functions of the revenue cycle, such as:

1. Patient Access;
2. Revenue Integrity;
3. Chargemaster;
4. Clinical Documentation Integrity (CDI);
5. Billing/Contracting; and
6. Health Information Management (HIM).

Determine what policies were changed with the PHE, and if those changes will continue after the PHE. Patient access may see changes in upfront collections. Revenue integrity will continue to charge for the COVID-19 treatments, but there will be changes in reimbursement for them. The chargemaster coordinator may need to update drugs that are utilized by the pharmacy, and/or the prices. The CDI team should continue to clarify COVID-19 status. Billing/contracting will need to be aware of the payment policies of non-Medicare payers to ensure accurate reimbursement.

And for my HIM friends, you will need to assign the COVID codes for diagnosis and treatment. As noted, an additional 20 percent is paid based on the reported codes. Also, continue to obtain a positive COVID-19 test to support the diagnosis when the patient is not tested at your facility, until the end of the federal fiscal year.

Lastly, update your facility-specific coding guidelines regarding the coding changes at the end of the PHE. The update will promote consistency among your coding staff.