Question:

Is CMS suspending most Medicare Fee-For-Service (FFS) medical reviews during the Public Health Emergency (PHE) for the COVID-19 pandemic?

Answer:

On March 30, 2020, CMS suspended most Medicare Fee-For-Service (FFS) medical reviews because of the COVID-19 pandemic. This included pre-payment medical reviews conducted by Medicare Administrative Contractors (MACs) under the Targeted Probe and Educate program, and post-payment reviews conducted by the MACs, Supplemental Medical Review Contractor (SMRC) reviews, and Recovery Audit Contractor (RAC). As states reopen and given the importance of medical review activities to CMS’ program integrity efforts, CMS expects to discontinue exercising enforcement discretion beginning on August 3, 2020, regardless of the status of the public health emergency. If selected for review, providers should discuss with their contractor any COVID-19-related hardships they are experiencing that could affect audit response timeliness. CMS notes that all reviews will be conducted in accordance with statutory and regulatory provisions, as well as related billing and coding requirements. Waivers and flexibilities in place at the time of the dates of service of any claims potentially selected for review will also be applied.

This question was answered in our annual Respiratory Therapy Reimbursement & Compliance Update webcast. For more hot topics relating to respiratory services, please visit our store or call us at 1.800.252.1578, ext. 2.

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