HW&Co. Revenue Cycle COVID-19 Updates

At HW&Co., we understand that COVID-19 is creating unique revenue cycle challenges. Below, we have compiled some important updates to help you make sense of recent changes.

Rest assured, we are keeping up with all the COVID-19 news and pronouncements, both federally and locally, and will keep you updated.  Please reach out with any questions you have, and visit our COVID-19 Resource Center for more information.


Telehealth Services Expansion

Under the 1135 Waiver, Medicare can reimburse for visits (office, hospital, and other) furnished via telehealth across the country, this includes the patient’s place of residence effective March , 2020.  Providers such as doctors, nurse practitioners, clinical psychologists and more will be able to offer telehealth to their patients.

  • CMS has provided additional access to Medicare Telehealth services for beneficiaries, including those in Skilled Nursing Facilities
  • Included under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act (CARES Act)
  • Includes E-visits

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MDS Waiver Clarification

In the fact sheet linked below, you may have read that CMS has waived the time-frame requirement for a facility to complete and submit a Minimum Data Set (MDS) assessment. Please do not misinterpret this to mean that the MDS assessment is not required during the COVID-19 emergency.

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  • In order to bill Medicare with the current Patient Driven Payment model (PDPM), an MDS must be completed and submitted
  • The Medicare Beneficiary Policy Manual states the Skilled Nursing Facility (SNF) must complete and MDS in order for Medicare to pay for services
  • Per the Medicare guidance (article below) the SNF may submit the MDS outside of the 14-day window; the claim should have the condition code DR to bypass normal edits

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COVID-19 Diagnosis Code Update

On March 18, 2020 the ICD-10-CM Coordination and Maintenance committee announced it will adopt the World Health Organization (WHO) diagnosis code for COVID-19.

  • U07.1 (COVID-19) Diagnosis Code is now effective April 1, 2020 instead of October 1, 2020 due to the need to capture reporting of this condition in claims submitted across the nation, as well as surveillance data
  • Use only for confirmed cases as the primary code with pneumonia and all other manifestations coded in addition to U07.1
  • Claims prior to April 1, 2020 should report confirmed cases of COVID-19 using B97.29 (other coronavirus as the cause of diseases classified elsewhere), per Centers for Disease Control and Prevention (CDC)

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Medicare Advantage

Medicare beneficiaries in a state that a governor has declared a State Emergency under 42 CFR 422.100(m) have access to additional Medicare benefits for a period of 30 days, or the date in the Governor’s declaration, based on Federal Law. Requirements of Medicare Advantage plans under CFR 422.100(m)(1).

  • Part A and Part B services, as well as Part C benefits at non-contracted facilities are covered if the facility participates in Medicare
  • Requirements for gatekeeper referrals, if applicable, waived in full
  • The enrollee is given the same cost sharing as if the service was provided at a plan-contracted facility
  • Changes that benefit the enrollee are effective immediately without a 30-day notification requirement as directed by CFR 422.111(d)(3)


Medicare sequestration of payments initially began on April 1, 2013.  As part of the CARES Act,  this sequestration of Medicare payments will be removed. This will be in place May 1, 2020 through December 31, 3020.


If you are in need of support, our Revenue Cycle department can assist with billing services and business office functions. Please reach out to one of our Healthcare Consultants with any questions you have.

Jenna Bennett Dottie Hauman Kelly Sorensen
Senior Healthcare Consultant Senior Healthcare Consultant Senior Healthcare Consultant
bennett@hwco.com hauman@hwco.com sorensen@hwco.com