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| The COVID-19 pandemic has unquestionably put the U.S. health care system in a tough spot. That health care system, with all its warts<ref name="PreskittHealth08">{{cite journal |title=Health care reimbursement: Clemens to Clinton |journal=Baylor University Medical Center Proceedings |author=Preskitt, J.T. |volume=21 |issue=1 |pages=40–4 |year=2008 |doi=10.1080/08998280.2008.11928358 |pmid=18209755 |pmc=PMC2190551}}</ref><ref name="FiferHealth16">{{cite web |url=https://www.asha.org/Articles/Health-Care-Economics-The-Real-Source-of-Reimbursement-Problems/ |title=Health Care Economics: The Real Source of Reimbursement Problems |author=Fifer, R. |publisher=American Speech-Language-Hearing Association |date=July 2016 |accessdate=21 August 2020}}</ref><ref name="HuckmanWhat20">{{cite web |url=https://hbr.org/2020/04/what-will-u-s-health-care-look-like-after-the-pandemic |title=What Will U.S. Health Care Look Like After the Pandemic? |author=Huckman, R.S. |work=Harvard Business Review |date=07 April 2020 |accessdate=21 August 2020}}</ref>, has arguably not done well to handle so many unanticipated health issues from a broad portion of the population.<ref name="HuckmanWhat20" /><ref name="DorsettPoint20">{{cite journal |title=Point of no return: COVID-19 and the U.S. healthcare system: An emergency physician’s perspective |journal=Science Advances |author=Dorsett, M. |volume=6 |issue=26 |at=eabc5354 |year=2020 |doi=10.1126/sciadv.abc5354 |pmid=32637627 |pmc=PMC7319747}}</ref><ref name="SlotkinHow20">{{cite web |url=https://hbr.org/2020/06/how-one-health-system-is-transforming-in-response-to-covid-19 |title=How One Health System Is Transforming in Response to Covid-19 |author=Slotkin, J.R.; Murphy, K.; Ryu, J. |work=Harvard Business Review |date=11 June 2020 |accessdate=21 August 2020}}</ref><ref name="MendelsonProvid20">{{cite web |url=https://www.forbes.com/sites/danielmendelson/2020/06/30/the-impact-of-covid-19-on-providers-risk-recession-and-reimbursement/ |title=The Impact Of COVID-19 On Providers: Risk, Recession And Reimbursement |author=Mendelson, D. |work=Forbes |date=30 June 2020 |accessdate=21 August 2020}}</ref><ref name="MITWhat21">{{cite web |url=https://news.mit.edu/2021/what-has-pandemic-revealed-about-us-health-care-what-needs-change-0405 |title=What has the pandemic revealed about the US health care system — and what needs to change? |work=MIT News |publisher=Massachusetts Institute of Technology |date=05 April 2021 |accessdate=13 September 2021}}</ref><ref name="ScottTheUS21">{{cite web |url=https://www.vox.com/policy-and-politics/22555949/us-health-care-system-ranking-covid-19-pandemic |title=The US health system was already falling short. Then Covid-19 happened. |author=Scott, D. |work=Vox |date=06 July 2021 |accessdate=13 September 2021}}</ref> From a provider side, proper reimbursement for COVID-19 testing is among the many issues that must be addressed. One key aspect of ensuring proper reimbursement in a reasonable time frame is first making sure a clear preregistration process that captures critical patient and facility information is conducted. (This can be facilitated and made easier as a first-step process in a clinical informatics solution, for example.) Critical patient and facility information includes (but is not limited to):
| | Like any other communicable disease, laboratories handling specimens that are suspected or confirmed of containing the SARS-CoV-2 virus must take appropriate precautions to protect all stakeholders. This involves not only any in-house protocols for preventing contamination but also any official guidance that goes beyond or supersedes in-house protocols. Examples of guidance documents include the World Health Organization's ''[https://www.who.int/publications/i/item/WHO-WPE-GIH-2021.1 Laboratory biosafety guidance related to coronavirus disease (COVID-19)]'', the CDC's ''[https://www.cdc.gov/coronavirus/2019-nCoV/lab/lab-biosafety-guidelines.html Interim Laboratory Biosafety Guidelines for Handling and Processing Specimens Associated with Coronavirus Disease 2019 (COVID-19)]'', and the CDC's ''[https://www.cdc.gov/coronavirus/2019-ncov/lab/lab-safety-practices.html Guidance for General Laboratory Safety Practices during the COVID-19 Pandemic]''. Additionally, it may be helpful to look to what other laboratories are doing. In a brief article published in ''The Lancet Microbe'', Choy highlights an International Federation of Clinical Chemistry and Laboratory Medicine Taskforce survey of biochemistry labs and how they've been mitigating biohazard risks associated with SARS-CoV-2. Actions include<ref name="ChoyChanges20">{{cite journal |title=Changes in clinical laboratory operations and biosafety measures to mitigate biohazard risks during the COVID-19 pandemic |journal=The Lancet Microbe |author=Choy, K.W. |volume=1 |issue=7 |pages=E273-E274 |year=2020 |doi=10.1016/S2666-5247(20)30168-3}}</ref>: |
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| * name, date of birth, and gender | | * restricting laboratorian access to testing of suspected and confirmed COVID-19 patient samples; |
| * race and ethnicity | | * tightening of delivery and shipping procedures of suspected and confirmed COVID-19 patient samples; |
| * demographic information such as full address and phone number
| | * limiting add-on test requests for suspected and confirmed COVID-19 patients; |
| * ordering physician or attending health care provider for test (if applicable) | | * increasing the frequency of disinfection; and |
| * facility's National Provider Identifier (NPI)
| | * considering the expanded use of autoclaving before sample disposition. |
| * patient insurance company name, policy ID, group ID, insured's name, and insured relationship to patient (if insured)
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| * whether or not it's the patient's first test (federal reporting requirement)
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| * whether or not the patient is a resident of a congregate care setting (federal reporting requirement; also, e.g., additional Medicaid reimbursement may be available in some states<ref name="FlinnStates20">{{cite web |url=https://www.leadingage.org/regulation/states-leverage-medicaid-provide-nursing-homes-lifeline-through-covid-19 |title=States Leverage Medicaid to Provide Nursing Homes a Lifeline through COVID-19 |author=Flinn, B. |work=LeadingAge |date=12 June 2020 |accessdate=21 August 2020}}</ref>)
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| * whether or not the patient is a healthcare worker (federal reporting requirement; also, e.g., may affect the patient's worker's compensation claim<ref name="DOLClaimsUnder20">{{cite web |url=https://www.dol.gov/agencies/owcp/FECA/InfoFECACoverageCoronavirus |title=Claims under the Federal Employees' Compensation Act due to the 2019 Novel Coronavirus (COVID-19) |author=Division of Federal Employees' Compensation |publisher=U.S. Department of Labor |date=06 May 2021 |accessdate=13 September 2021}}</ref><ref name="MichiganWorkers20">{{cite web |url=https://www.michigan.gov/ag/0,4534,7-359-98784_98791-523085--,00.html |archiveurl=https://web.archive.org/web/20200821194015/https://www.michigan.gov/ag/0,4534,7-359-98784_98791-523085--,00.html |title=Worker's Compensation for First Responders |author=Department of Attorney General |publisher=State of Michigan |date=2020 |archivedate=21 August 2021 |accessdate=13 September 2021}}</ref>) | |
| * whether or not the patient is pregnant (federal reporting requirement; also, e.g., Medicare will ''only'' accept a COVID-19 code as secondary if the primary diagnosis code is viral disease complicating pregnancy, childbirth, or puerperium<ref name="HSRACOVID20">{{cite web |url=https://www.hrsa.gov/CovidUninsuredClaim |title=COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing and Treatment of the Uninsured |publisher=Health Resources & Services Administration |date=May 2020 |accessdate=21 August 2020}}</ref><ref name="ACEPCoding20">{{cite web |url=https://www.acep.org/administration/reimbursement/covid-19/ |title=Coding Guidance for COVID-19 |publisher=American College of Emergency Physicians |date=2020 |accessdate=21 August 2020}}</ref>) | |
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| Secondarily, it's also important to have a plan in place for testing the uninsured. While the Families First and Coronavirus Relief Act (FFCRA) and the National Disaster Management System (NDMS) have historically provided legal mechanisms for reimbursement for what should otherwise be free patient testing for SARS-CoV-2 and the associated visit, ambiguities of these mechanisms and how they were enforced still managed to cause problems.<ref name="AdlerTheLaws20">{{cite web |url=https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/07/13/the-laws-governing-covid-19-test-payment-and-how-to-improve-them/ |title=The laws governing COVID-19 test payment and how to improve them |author=Adler, L.; Young, C.L. |work=USC-Brookings Schaeffer Initiative for Health Policy |publisher=Brookings Institution |date=13 July 2020 |accessdate=21 August 2020}}</ref> For example, while providers could turn to the NDMS (until funds ran out) to pay uninsured claims at 110% of Medicare rates—with states' opting to cover those costs through their Medicaid program—providers were not obligated by the law to seek reimbursement from those entities and could optionally bill the uninsured patient directly, which was against the spirit of the FFCRA.<ref name="AdlerTheLaws20" /><ref name="DawsonTheNat20">{{cite web |url=https://www.kff.org/coronavirus-covid-19/issue-brief/the-national-disaster-medical-system-ndms-and-the-covid-19-pandemic/ |title=The National Disaster Medical System (NDMS) and the COVID-19 Pandemic |author=Dawson, L. |work=KFF |date=22 April 2020 |accessdate=21 August 2020}}</ref><ref name="CRSHealth20">{{cite web |url=https://crsreports.congress.gov/product/pdf/R/R46316 |title=Health Care Provisions in the Families First Coronavirus Response Act, P.L. 116-127 |author=Congressional Research Service |date=17 April 2020 |accessdate=21 August 2020}}</ref> Given these past problems and any lingering questions about existing programs like the HHS and HRSA coverage assistance programs<ref name="HSRACOVID20" />, it's important to know what your lab's policy will be on managing uninsured patient claims. How will you get reimbursed if you're accepting uninsured patients? Resources that may help with these decisions include the Health Resources & Services Administration's [https://www.hrsa.gov/CovidUninsuredClaim information page] and [https://www.hrsa.gov/coviduninsuredclaim/frequently-asked-questions associated FAQ].
| | Additional aspects of operations that laboratory managers may wish to implement include "number of shifts per day, the number of staff per shift, total number of staff accessible to work in the laboratory, shift change frequency, team-splitting arrangements, and fixed work–rest days."<ref name="ChoyChanges20" /> Arranging staff into smaller teams while reducing the consecutive number of shifts worked may reduce risks; however, managers of labs struggling to meet turnaround times may feel like this isn't realistically possible. In the end, the safety of personnel must be of highest importance, even while trying to rapidly and accurately conduct COVID-19 testing.<ref name="ChoyChanges20" /> |
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| For Medicare, Medicaid, and otherwise insured patients, the lab will likely have (or presumably acquire) someone on hand with billing experience. However, the preregistration information previously mentioned will still be important to implement. And staying up-to-date regarding billing issues is also important (e.g., CMS' October 2020 announcement about payment for high-throughput COVID-19 tests and turnaround times<ref name="CMSChanges20">{{cite web |url=https://www.cms.gov/newsroom/press-releases/cms-changes-medicare-payment-support-faster-covid-19-diagnostic-testing |title=CMS Changes Medicare Payment to Support Faster COVID-19 Diagnostic Testing |work=CMS Newsroom |publisher=Centers for Medicare & Medicaid Services |date=15 October 2020 |accessdate=20 November 2020}}</ref>
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| For further guidance on billing issues, you may wish to consult with CMS' [https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf extensive document] titled ''COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing''. Also, the next chapter addresses code sets for reporting and billing, which may prove useful.
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| ==References== | | ==References== |
| {{Reflist|colwidth=30em}} | | {{Reflist}} |
Like any other communicable disease, laboratories handling specimens that are suspected or confirmed of containing the SARS-CoV-2 virus must take appropriate precautions to protect all stakeholders. This involves not only any in-house protocols for preventing contamination but also any official guidance that goes beyond or supersedes in-house protocols. Examples of guidance documents include the World Health Organization's Laboratory biosafety guidance related to coronavirus disease (COVID-19), the CDC's Interim Laboratory Biosafety Guidelines for Handling and Processing Specimens Associated with Coronavirus Disease 2019 (COVID-19), and the CDC's Guidance for General Laboratory Safety Practices during the COVID-19 Pandemic. Additionally, it may be helpful to look to what other laboratories are doing. In a brief article published in The Lancet Microbe, Choy highlights an International Federation of Clinical Chemistry and Laboratory Medicine Taskforce survey of biochemistry labs and how they've been mitigating biohazard risks associated with SARS-CoV-2. Actions include[1]:
- restricting laboratorian access to testing of suspected and confirmed COVID-19 patient samples;
- tightening of delivery and shipping procedures of suspected and confirmed COVID-19 patient samples;
- limiting add-on test requests for suspected and confirmed COVID-19 patients;
- increasing the frequency of disinfection; and
- considering the expanded use of autoclaving before sample disposition.
Additional aspects of operations that laboratory managers may wish to implement include "number of shifts per day, the number of staff per shift, total number of staff accessible to work in the laboratory, shift change frequency, team-splitting arrangements, and fixed work–rest days."[1] Arranging staff into smaller teams while reducing the consecutive number of shifts worked may reduce risks; however, managers of labs struggling to meet turnaround times may feel like this isn't realistically possible. In the end, the safety of personnel must be of highest importance, even while trying to rapidly and accurately conduct COVID-19 testing.[1]
References
- ↑ 1.0 1.1 1.2 Choy, K.W. (2020). "Changes in clinical laboratory operations and biosafety measures to mitigate biohazard risks during the COVID-19 pandemic". The Lancet Microbe 1 (7): E273-E274. doi:10.1016/S2666-5247(20)30168-3.
