Here’s an excerpt of an 11-page checklist developed by PYA. View the entire checklist at https://bit.ly/3li7rpW. Contact Martie Ross, a consulting principal with PYA, at mross@pyapc.com and Kathy Reep, a senior manager with PYA, at kreep@pyapc.com.
Example Checklist
READ ME: The end of the COVID-19 public health emergency (PHE) means the end of federal regulatory waivers and flexibilities. Providers must now roll back policies and practices implemented in reliance on those waivers and flexibilities. Unless stated otherwise, return to normal operations must be completed before May 12, 2023.
PYA has prepared this checklist to help providers identify the work to be done by that date. Rather than summarizing each waiver and flexibility (e.g., “CMS changed the timeline from 5 to 21 days”), the checklist states the rule that will be in effect following the end of the PHE (e.g., “The timeline is 5 days”). For each item, we cite the relevant regulation, as applicable.
This checklist focuses primarily on waivers and flexibilities relating to the Medicare program. It does not address the following:
-
Waivers and flexibilities made permanent or terminated prior to 1/1/2022
-
Reimbursement for COVID-19 vaccinations, testing, and treatment
-
Modifications to Medicare value-based purchasing programs
-
CMS-approved state Medicaid program waivers and flexibilities
-
State and local waivers and flexibilities
Note the following are not impacted by the end of the PHE. Any changes to or discontinuation of these requirements will be the subject of separate regulatory action:
-
Food and Drug Administration (FDA) emergency use authorization for COVID-19 vaccines, tests, and treatments
-
Hospital and long-term care facility COVID-19-related reporting requirements
-
Health care provider vaccine mandates
-
Occupational Safety and Health Administration’s (OSHA)’s Healthcare Emergency Temporary Standard
-
Duties and obligations relating to Provider Relief Fund payments
We have categorized the waivers and flexibilities by the type of provider most directly impacted. Because a waiver or flexibility may impact more than one provider type, one should review each section to identify all relevant post-PHE changes.
This checklist is current as of the date of publication noted below. PYA will update the checklist as additional guidance becomes available. This checklist does not constitute and cannot be relied upon as legal, tax, accounting, banking, financial, or any other form of professional or other advice. We have made a reasonable effort to address all waivers and flexibilities, but we do not and cannot warrant the completeness of this checklist.
1. Applicable to Multiple Provider Types |
---|
A. Medicare Provider Enrollment
|
B. Medicare Appeals
|
C. COVID-19 Diagnostic Testing and Reporting
|
D. State licensure requirements
|
E. Fraud and abuse
|