Highlighted Posts

Posts from July 2020.
On July 30, 2020, the Centers for Medicare & Medicaid Services (CMS) announced that new procedure codes are being implemented to allow Medicare to identify the use of the therapeutics remdesivir and convalescent plasma for treating hospital in-patients with COVID-19. These codes will be effective August 1, 2020 and are intended to assist ...
On July 29, 2020, the Department of Health and Human Services Office of Inspector General (OIG) updated its FAQs published in response to inquiries from the healthcare community on the application of the OIG’s administrative enforcement authorities to arrangements connected to the COVID-19 public health emergency. More specifically, the ...
On July 28, 2020, the Department of Health and Human Services released a new report showing utilization trends of telehealth services for fee-for-service Medicare services. Based on claims data collected from January through early June, the report found that in response to the COVID-19 public health emergency (PHE) and the waiver of ...
In response to the COVID-19 public health emergency (PHE), the Centers for Medicare & Medicaid Services (CMS) published numerous 1135 blanket waivers (available here) to help counteract the strains and limitations placed on healthcare providers caused by the virus. On July 24, 2020, the American Health Lawyers Association published a ...
On July 29, 2020, Governor Beshear reiterated that an order from a licensed clinician is not necessary for laboratory service providers to perform and bill for FDA-approved COVID-19 diagnostic tests. Additionally, pursuant to the Cabinet for Health and Family Services Department for Public Health Order, health insurers may not require a ...
On July 30, 2020, the Centers for Medicare & Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC) revised its billing guidance to allow for payment to healthcare professionals who counsel patients, at the time of COVID-19 diagnostic testing, about the importance of self-isolating following testing and prior to the ...

Written by:  Marianna Michael

On July 27, 2020, the Supreme Court of Kentucky entered two new orders to provide continuing guidance on the functions of courts during COVID-19.

The first order, Administrative Order 2020-55, replaces Administrative Orders 2020-42 and 2020-47 in their entirety.  The Order makes the following provisions: 

Read more

Written by:  Marianna Michael

On July 27, 2020, the Supreme Court of Kentucky entered two new orders to provide continuing guidance on the functions of courts during COVID-19.

The first order, Administrative Order 2020-55, replaces Administrative Orders 2020-42 and 2020-47 in their entirety.  The Order makes the following provisions:

Read more

Written by:  Marianna Michael

In three recent letters, the Department of Labor (“DOL”) offered guidance on the outside sales exemption and the retail or service establishment exemption.

An employer qualifies for the outside sales exemption if its employee’s: (i) primary duty is to make sales (as defined in the Fair Labor Standards Act ...

As previously reported, Congress has been weighing legislation that would make some changes and expansions to telehealth services permanent following the conclusion of the COVID-19 public health emergency. On July 15, 2020, the director of the Centers for Medicare & Medicaid Services (CMS), Seema Verma, published a blog analyzing the data  ...
Last week, hospitals were directed to bypass the Centers for Disease Control and Prevention (CDC) National Healthcare Safety Network and report coronavirus-related information directly to the Department of Health and Human Services (HHS). More information on the shift of reporting is also available here. This week, HHS launched its ...
On July 23, 2020, Secretary of Health and Human Services Alex Azar renewed the determination that a Public Health Emergency related to the COVID-19 pandemic exists. Secretary Azar first declared the COVID-19 Public Health Emergency on January 27, 2020 and first renewed that declaration on April 21. This renewal was due to expire on July 25. The  ...
The Centers for Medicare & Medicaid Services (CMS) has announced an additional $5 billion of funding from the Provider Relief Fund will go to Medicare-certified long term care facilities to support the enhancement of nursing homes’ response to COVID-19. These funds are meant to assist facilities with enhancing infection control, building ...

(NOTE: This article includes updates as of Tuesday, August 4, 2020.)

by Kathie McDonald-McClure, Partner

On January 27, 2020, the White House administration declared a public health emergency (PHE) due to the novel coronavirus (COVID-19).  On March 6, 2020, Governor Beshear declared a state of emergency, making it only the fifth U.S. state to ...

The new guidance provides plain-language FAQs addressing critical issues under all three laws. Specifically, the FAQs address questions about telework, telemedicine, and the new paid sick leave and expanded family and medical leave law. The guidance reiterates common knowledge like “employees must be compensated for all hours worked” ...

Governor DeWine has signed into law some important changes to the Ohio workers’ compensation system.  The changes, codified in H.B. 81, will go into effect on September 14, 2020.  Here are the highlights:

  • Statute of Limitations – An application for an additional award for a violation of a specific safety requirement (VSSR) must now be filed ...
On July 9, 2020, Gov. Andy Beshear announced $36,200,000 in assistance for Kentucky’s local public health departments from the Coronavirus Aid, Relief and Economic Security (CARES) Act. These funds will allow the health departments to continue providing essential, front-line public health services in the battle against COVID-19  ...
On July 10, 2020, the Kentucky Cabinet for Health and Family Services (CHFS) issued guidance to health care facilities clarifying that the lab result is the source document for billing start/stop dates. Billing starts when the positive test result is received and continues until the COVID-19 resident is released from isolation (i.e ...
On July 10, 2020, the Department of Health and Human Services (HHS) announced that approximately $3 billion of Provider Relief Funds will go to hospitals serving vulnerable populations on thin margins. Many of these hospitals may have missed out on earlier fund distributions due to their low Medicare patient populations. An additional $1 ...

On Friday, July 17, 2020, Indiana Governor Eric Holcomb issued Executive Order 20-36 announcing that the state would stay in Stage 4.5 of the “Back-On-Track Indiana” reopening plan.  Stage 5 had been scheduled to begin on July 4, 2020 but was replaced by Stage 4.5, which began on July 3, 2020, due to modest evidence of a resurgence of COVID-19 ...

On July 14, 2020, the Internal Revenue Service extended the deadline for hospitals to conduct a community health needs assessment (CHNA). Healthcare organizations that claim non-profit status are required to complete a CHNA every three years, but the COVID-19 emergency has significantly interfered with hospitals’ ability to timely and  ...

On Wednesday, July 15, 2020, Attorney General Daniel Cameron filed a motion in the Boone County Kentucky Circuit Court seeking to invalidate all executive orders issued to date by Governor Andy Beshear directed at containing the spread of COVID-19, a highly contagious disease that prompted the declaration of a national public health emergency ...

Recent surges in COVID-19 cases are straining health care providers’ already low supply of personal protective equipment (PPE). Despite efforts to increase production and distribution of PPE since the COVID-19 public health emergency began, as well as efforts such as decontaminating N95 masks to extend the useful life of PPE, shortages of  ...

Written by:  Mitzi D. Wyrick

The Wage and Hour Division (WHD) of the U.S. Department of Labor (DOL) published streamlined forms for employers and employees to use in requesting leave under the Family and Medical Leave Act (FMLA).  The DOL has attempted to make the new forms easier for employers and employees to understand and use.  For example, more ...

On July 6, 2020, CMS updated MLN Matters Article SE20016  to clarify how Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) can apply the Cost Sharing (CS) modifier to preventive services furnished via telehealth. The update includes:

  • Additional claim examples
  • New section on the RHC Productivity Standard
There are ...

On July 8, 2020, the Centers for Medicare & Medicaid Services (CMS) revised its MLN Matters Article SE20011 on “Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)”.  One revision addresses services provided by the hospital in the patient’s home as a provider-based outpatient ...

Although Congress is currently considering legislation to permanently implement the temporary telehealth expansion waivers implemented in response to the COVID-19 public health emergency, providers should carefully monitor current federal and state telehealth requirements in the event that the telehealth waivers lapse before ...
On July 9, 2020, the Department of Health and Human Services, through the Health Resources and Services Administration, awarded $17 million to support Health Center Look-Alikes (LALs) in their COVID-19 response efforts. Health Center LALs are Health Resources and Service Administration award recipients that serve vulnerable populations or ...
On July 7, 2020, in response to surging COVID-19 cases across the country, the Department of Health and Human Services announced free COVID-19 testing in Jacksonville, Florida; Baton Rouge, Louisiana; and Edinburg, Texas. COVID-19 testing at these virus hotspots is available to anyone who is experiencing symptoms, may have been exposed to ...
In response to the rapid spread of COVID-19 across the country and the rising number of cases in Kentucky, on July 9, 2020, Governor Beshear announced that effective at 5 p.m. on Friday, July 10, people in Kentucky must cover their nose and mouth with a face covering in several enumerated situations that present a high risk of COVID-19 transmission  ...
Two Kentucky organizations, the Fair Elections Center and the Kentucky Equal Justice Center, filed suit on behalf of four voters who have health conditions and say that in-person voting would put them at serious risk of contracting COVID-19 during the ongoing public health emergency. The suit seeks to require election officials to apply the ...

The Centers for Medicare & Medicaid Services (CMS) requires that all eligible hospitals use the 2015 Edition certified electronic health record technology (CEHRT) to meet the requirements of the Promoting Interoperability Programs. CMS mandates downward payment adjustments be applied to eligible hospitals that are not meaningful users ...

There is good news and bad news when it comes to Ohio’s unemployment situation.  Let’s get the bad news out of the way first: Ohio’s unemployment rate is still very high.  The good news, however, is that Ohio is extending its unemployment benefits for up to 20 weeks in light of this COVID-induced unemployment.

The extended benefit will apply to ...

Today, in Our Lady of Guadalupe School v. Morrissey-Berru, the U.S. Supreme Court barred employment discrimination suits by two Catholic grade school teachers, holding that, “Courts are bound to stay out of employment disputes involving those holding certain important positions with churches and other religious institutions.”

The ...

As we reported in Wyatt’s weekly COVID-19 Newsletter on July 2, 2020, the U.S. Department of Health & Human Services (HHS), announced on June 29, 2020 an agreement to secure more than 500,000 treatment courses of the drug remdesivir for the United States from Gilead Sciences through September.  As Gilead’s donated supply of remdesivir has ...

CMS collects data every 3 years on the occupational mix of employees for each short-term, acute care hospital participating in the Medicare program. Completed 2019 Occupational Mix Surveys, Hospital Reporting Form CMS-10079, for the Wage Index Beginning FY 2022, are due to the Medicare Administrative Contractors (MACs) on the Excel ...

CMS updated the COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing  by adding or updating the following numerous FAQs for the following areas of billing:

  • Laboratory Diagnostic Services, FAQs 9-13.
  • Hospital Outpatient – Locations Off Campus, FAQs 2-17
  • Hospital Outpatient Therapeutic Services Furnished ...
On June 29, 2020, HHS announced an agreement to secure more than 500,000 treatment courses of the drug remdesivir for the United States from Gilead Sciences through September, allowing American hospitals to purchase the drug at the Wholesale Acquisition Cost (WAC) of approximately $3,200 per treatment course.  Additional supplies of ...

While the Public Health Emergency (PHE) due to COVID-19 is set to expire on July 25, 2020, on June 29th, an HHS spokesperson confirmed that HHS intends to renew it.  Amidst growing concerns that it may expire, the American Hospital Association sent a letter to the Secretary of HHS urging renewal.  In response, Michael R. Caputo, HHS Assistant ...

The Wage and Hour Division of the Department of Labor (“DOL”) recently gave us the gift we never knew we needed all wrapped in a nice bow. What do I mean? On top of all of the other guidance that has been released by the DOL and the EEOC the past few weeks, the DOL decided to issue five new opinion letters on FLSA issues. Two of the letters concern the ...

On June 25, 2020, the Kentucky Cabinet for Health & Family Services (CHFS) provided guidance to long term care providers concerning the resumption of certain activities. Beginning June 29, all long term care facilities may resume recreational and therapeutic group activities, communal dining, and transportation for non-emergent off-site  ...
On June 23, 2020, CHFS issued Provider Guidance: Re-Opening Adult Day Health Care Centers, which provides information to licensed Adult Day Health Care Centers concerning the resumption of on-site services on June 29 provided certain conditions are met.
On June 23, 2020, CHFS issued Provider Guidance: Adult Day Training In-Person Services, which provides clarifying information to Adult Day Training Medicaid Waiver Providers concerning the resumption of in-person services on June 29 provided certain conditions are met.

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