Frequently Asked Questions During This COVID-19 Crisis

DISCLAIMER:  The information that follows is provided as a service by the Michigan Podiatric Medical Association (MPMA) for the purpose of education, communication, and information.  Please note, these are opinions only.  The MPMA accepts no liability relative to the contents, accuracy or use of these services. Nothing in these FAQs is intended to be construed as legal advice. The user is strictly cautioned to seek legal assistance when attempting to determine any legal rights, responsibilities and procedures with respect to business affairs, coding, or other legal aspects of operating a practice. MPMA disclaims any and all liability for injury and/or other damages which result to a user from the material offered or discussed herein.

Q: I would like to know is how are other Michigan Podiatrist dealing with this situation involving nursing facilities?
A: With the nature of the disease attacking older, unhealthy populations, COVID makes a tough situation even tougher for nursing home patients, administrators and health care providers. As one quarter of all the deaths in Michigan have come in nursing homes, nobody can take the approaches to nursing homes lightly.  Therefore, the MPMA to encourages its members to defer to the nursing home administrators.  Work with the administrators to keep everything as hygienic and safe for everyone (patients, staff and doctors) as possible. Those facilities have a lot of liability exposure right now in addition to being in the middle of the spotlight. If you are a physician entering nursing care facilities, be sure to discuss the situation with your own liability carrier in case your carrier has additional requirements for you.

Q:  What EXACTLY does the Executive Order related to health care temporary restrictions say?
Click here for the actual Executive Order issued by Governor Gretchen Whitmer.  Additionally, click here for FAQs specific to the health care temporary restrictions.

Q:  How should I pre-screen my patients before they arrive at my office?
The CDC recommends you screen patients for symptoms of acute respiratory illness.  Ask them if they have a fever, a cough, or difficulty breathing as these are symptons of COVID-19.  Ask these BEFORE entering your healthcare facility.  Also ask if they have used any forms of public transportation recently (flight, bus, etc.).  Remind your patients that other people should not accompany them to your office.  If others are required, make sure those others are pre-screened as well.

Q: What suggestions do you have for I should run my waiting room at this time?
If possible, avoid the waiting room all together.  Have your patients wait in their vehicles until you are able to treat them directly in your patient rooms.  Limit the number of people in your office by allowing only patients into your office.  Try to avoid other people accompanying your patients to your office.  If others are required, make sure those others are pre-screened.  And be sure to thoroughly clean and wipe down all surfaces, arm chairs, door knobs, etc. frequently.

Q:  What do you mean by "provide a safe environment" in my office?
Ensure that all of your staff properly use personal protection equipment (PPE). Encourage sick employees to stay home. Personnel who develop respiratory symptoms (e.g., cough, shortness of breath) should be instructed not to report to work. Ensure that your sick leave policies are flexible and consistent with public health guidance and that employees are aware of these policies.  Limit the number of people in your office, and ensure that social distancing (at least 6 feet of separation) is maintained.

Q: I understand I can use telemedicine.  How do I do that?
Yes, you can.  To learn more, we recommend you take a look at the APMA webinar devoted to this topic. Click here to view the APMA Telemedicine Webinar.

The Centers for Medicare and Medicaid Services (CMS) has announced major changes to services that podiatrists can furnish remotely under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act. This waiver allows Medicare to pay for office, hospital, and other visits furnished via telehealth. This change means podiatrists can submit CPT 99201–99215 when these services are provided remotely.

Any device that has interactive audio and video and allows real time communication may be used. Providers are permitted to reduce or waive cost-sharing for these services if they wish during the Public Health Emergency. Additionally, CMS shared that typical HIPAA guidance does not apply to these services as long as health-care providers are providing these services in good faith. FaceTime and Skype were given as examples of services we can use to provide these services.

When submitting these services, the normal CPT 99201–99215 codes may be used and no special modifiers are necessary. Place of Service “02” (the location where health services and health related services are provided or received, through a telecommunication system) should be used when submitting these claims. Evaluation and management services will be paid at the facility rate and, when medically necessary, can be provided for any pathology, whether or not it is related to COVID-19.

Q: Is there any type of consent form needed for telemedicine?
The MPMA encourages you to contact your liability coverage provider to see if they have a sample form for you to use.  If PICA is your carrier, click here to use the PICA approved consent form.

Q:  Has CMS given any instructions or announced changes about Medicare quality reporting programs?
Yes, CMS announced it is granting exceptions from reporting requirements and extensions for clinicians and providers participating in Medicare quality reporting programs with respect to upcoming measure reporting and data submission for those programs. The action comes as part of the Trump Administration's response to 2019 Novel Coronavirus (COVID-19).

CMS is implementing additional extreme and uncontrollable circumstances policy exceptions and extensions for upcoming measure reporting and data submission deadlines for several CMS programs. For those programs with data submission deadlines in April and May 2020, submission of those data will be optional, based on the facility's choice to report.

CMS recognizes that quality measure data collection and reporting for services furnished during this time period may not be reflective of their true level of performance on measures such as cost, readmissions, and patient experience during this time of emergency and seeks to hold organizations harmless for not submitting data during this period.

Q: Is there any Medicare provider enrollment relief available at this time?
Yes, click here for some helpful FAQs on Medicare provider enrollment relief.

Q:  How do I renew my license at this time?
Due to the COVID-19 pandemic, the LARA Bureau of Health Licensing office are closed and staff are working remotely.  The staff are uable to answer phone calls at this time.  You should submit all question to the Bureau of Professional Licensing via email at [email protected] .  The Bureau of Professional Licensing also encourages you to send documents needed for licensure to [email protected] and avoid using the US Mail.

Q:  What should I tell my patients if my office is closed?  Should I send them to the ER?
Because many hospitals are at or near capacity, please avoid referring patients to the ER.  Instead, each office should be responsible for arranging care with other physicians.

Q: What role does podiatry play in this COVID crisis?
Click here for a great article from JAPMA.