Most advice on remote work aims to persuade managers that it is awesome.  Here and now, managers need not be convinced; COVID-19 may be forcing the transition. The question is how to make the leap with no prior planning and little money.

The good news is that most DME suppliers can move employees offsite with seven basic tools.

First, a few clarifications:

• While this article is focused on medical billers, suppliers can apply it to a wide array of personnel that need to work from home.
• This article is for employees that need to work from home for reasons other than being sick or caring for the sick.
• To protect sensitive data, be sure to read privacy policies, security provisions, terms and conditions, and other documentation before implementing any new service.

1. Everyone Needs a Computer

To start working remotely, DME medical billers need a computer with a reliable internet connection. Luckily, there are apps and services for almost every other basic office function.

Security and control of all data is still important, so companies should avoid the use of personal computers and devices. Instead, employers can send work computers home, even desktop machines.  Before doing so:

• Install disk-level encryption software, like Microsoft’s Bitlocker or Veracrypt.
• Create an inventory of the items distributed, including cables and peripheral devices.
• Communicate in writing the rules for using work computers at home are the same as inside the office. That means, for example, work computers should be used for work purposes only, and there is no expectation of employee privacy when using company equipment.

… and Dual Monitors

When working remotely, paper is bad juju. Dual monitors are key to avoiding paper.  Employees are inclined to print, especially for projects that require document comparison. A second monitor allows workers to see the source document on one screen and research or update billing software on the other; no printing required.

… and Noise-Cancelling Headphones.

Not everyone has access to a quiet place to work at home. At MiraVista, we use Plantronics Voyager 8200 UC wireless headphones with active noise cancelling. We use them to drown out distractions, listen to music and coffeeshop sounds, and make voice and video calls with clients.  Additionally, the noise-canceling microphone is magical in its ability to mask not-very-business-like-background sounds we don’t want our clients to hear during business calls.  Seriously, they rule, and we consider them a key piece of our remote work kit.

2. Phone

Consider voice-over-IP options with desktop phone apps so employees can make and receive calls without giving out personal cell phone numbers.  We use Nextiva, but options are plentiful. Most legacy phone systems allow employees to forward their regular extensions to the virtual extension.

3. Fax

There are infinite options for electronic fax capability. We use Faxage for secure inbound and outbound faxing.

4. Email

If company email is not already accessible outside the office, consider creating separate, company-controlled email accounts on web-based platforms like Google’s G Suite or Rackspace.

5. Printer

Again, remote workers should avoid creating paper documents when working remotely. CutePDF enables users to print almost anything from any application to a pdf document for easy digital storage.

6. Remote Desktop

If the company’s billing software is not already in the cloud, consider using a secure remote desktop application to access office computers or servers over the Internet.  Popular services include:

• Microsoft Remote Desktop Connection.
• Chrome Remote Desktop.
• Splashtop.
• TeamViewer.

7. Document Storage

If the current billing application can electronically store documents, use that. Otherwise, consider a secure option from Box, Google Drive File Stream, or Dropbox. If current processes rely heavily on paper, managers may assign one or more people in the office (or a secure remote location with a scanner) to prioritize digitizing and saving paper documents for access by remote employees.

This is not an exhaustive list, but it will enable suppliers to get staff up and running at home quickly and inexpensively. Once functional, each business can adjust conditions and culture to suit its specific needs. Practice, after all, makes perfect.

Congress recently passed H.R. 6201, a bill to assist communities and change how employers handle employee leave during the COVID-19 (coronavirus) public health emergency. The heavily revised version of the bill passed the House on March 13 with 110 pages of text, but the approved language missed several critical edits necessary for the Senate’s consideration.  On March 16, the House finalized the technical edits via H. Res. 904 and sent it over to the Senate. On March 18, the bill cleared the Senate, and the President signed the legislation into law just hours later.  The bill takes effect immediately. 

Main Provisions of the Bill

H.R. 6201 provides assistance to affected individuals between the declaration of the public health emergency on January 31, 2020 and December 31, 2020, though each section may have a slightly different beginning or end date for administrative purposes. The legislation contains six notable provisions that we have placed into two categories:

1. Increased Business Regulations:
   • Payroll tax credits for new COVID-19 FMLA and paid sick leave benefits.
   • Emergency Family Medical Leave Act (FMLA) expansion.
   • Emergency paid sick leave.
2. Community Assistance:
   • Nutrition waivers.
   • Unemployment insurance stabilization.
   • Health provisions (COVID-19 testing and procedures).

Increased Business Regulations

The business regulations of the law do two primary things: expand FMLA and create new rules for the payment of sick leave related to COVID-19.  The law also introduces a payroll tax credit to offset employer expenses related to the expanded provisions.

Emergency Family Medical Leave Act (FMLA) Expansion – The legislation expands certain FMLA provisions to include businesses with 500 or fewer employees.  As such, most companies will have to offer employees certain job security protections during the COVID-19 public health emergency.

Businesses must allow employees to take leave when they are unable to work (or telework) because they must care for a son or daughter under the age of 18 due to a school or day care closing. The first 10 days of leave can be unpaid, but the remainder, up to a maximum of 12 weeks, must be paid at a rate of no less than 2/3 of their regular pay rate. The maximum rate of pay is capped at $200/day and $10,000 in aggregate). Businesses must keep jobs open for returning employees.

The Secretary of Labor has the authority to exempt small businesses with fewer than 50 employees if the imposition jeopardizes the viability of the business. Employers of health care workers and emergency responders can elect to exclude employees from the new FMLA protections.

Emergency Paid Sick Leave – Private businesses with fewer than 500 employees and public entities with more than 1 employee must provide paid sick leave for employees that are unable to work (or telework) due to:

1. A federal, state, or local quarantine related to COVID-19.
2. The recommendation by a healthcare provider to self-quarantine due to COVID-19.
3. Symptoms of COVID-19 where the employee is seeking a medical diagnosis.
4. A need to care for a family member subject to quarantine related to COVID-19.
5. The need to care for a son or daughter after a school or day care closure or the unavailability of a childcare provider due to COVID-19 precautions.

At a minimum, employers must offer full-time employees up to 80 hours of paid sick time for these qualifying events. Part-time employees are entitled to the average number of hours normally worked in a two-week period. Leave related to self-care is compensated at the employee’s regular rate of pay (up to a maximum of $511/day); leave where the employee is acting as a caregiver is paid at 2/3 of their regular rate (up to a maximum of $200/day). Paid sick time will not carry over from one year to the next.

Employees cannot be discharged, disciplined, or discriminated against for taking leave.

The Secretary of Labor has the authority to exempt small businesses with fewer than 50 employees if the imposition would jeopardize the viability of the business. The Secretary can also permit employers of health care workers and emergency responders to exclude certain employees from the new FMLA protections.

Payroll Tax Credits – Private businesses that employ fewer than 500 employees are eligible for a payroll tax credit for FMLA and emergency paid sick leave related to COVID-19.  The credit should allow business to recover most, if not all, of the newly mandated expenditures. The tax credit is not applicable to publicly-owned federal, state, or local government entities.

Community Assistance

Nutrition Waivers - Nutrition waivers allow for innovation and flexibility during the COVID-19 public health emergency so meals reach students, families, and vulnerable adults. The support affects various programs and technologies including WIC, SNAP, schools, and EBT. 

Unemployment Insurance Stabilization - In anticipation of a spike in unemployment, the federal government will provide additional funds and flexibility to states if unemployment rates increase by 10% in any given quarter.

Health Provisions – The bill requires all insurers to pay the entire cost of COVID-19 testing and related office visits. Insurers cannot pass portions of covered items to beneficiaries through deductibles, co-payments, or other cost-sharing arrangements.  The bill also provides an opportunity for states to cover COVID-19 testing and diagnosis for uninsured individuals during the emergency period. 

We will continue to monitor for any developments from the Secretary of Labor as they relate to small businesses with 50 or fewer employees and any healthcare worker or emergency responder exemptions. 

SOURCE LINKS
https://docs.house.gov/billsthisweek/20200309/BILLS-116hr6201-SUS.pdf
https://www.congress.gov/bill/116th-congress/house-resolution/904/text

Amid concerns that dwindling numbers of enrolled DME suppliers were depleting rural patients’ access to necessary equipment and services, CMS increased rural payment amounts in June 2018. To do so, the agency averaged the adjusted fee schedule rates derived from competitively bid single payment amounts with higher unadjusted amounts in affect before the adjusted rates took effect. Rural suppliers have survived on these 50/50 blended rates for almost two years, but they are scheduled to expire on December 31, 2020.

CMS, absent legislation, is not likely to extend relief after 2020 because the agency believes competitive bid reform will deliver more sustainable rates through the Round 2021 contracts that take effect on January 1, 2021. The industry, understandably, remains skeptical the reform-driven rates can sustain suppliers or stabilize patient access to care.

The Protecting HOME Act (H.R. 2771) could provide legislative relief.  The currently pending legislation contains protections for sustainable rates outside competitively bid areas, both rural and non-rural. It:

• Permanently continues the 50/50 blended rate for rural areas, and
• Requires CMS to calculate payments in non-rural areas using a blend of the unadjusted fee schedules (25%) and competitive bidding fee schedules (75%).

Though it currently has 75 co-sponsors, the bill requires many more to gather enough momentum to either pass the House independently or transfer its provisions to a general spending bill at the end of the year.

One hopes for rational legislation, but …

There is a real possibility that rural suppliers will have to absorb rate cuts on traditional products like CPAP, oxygen, beds, and support surfaces, as well as competitively bid Round 2021 products like ventilators and braces. Aside from urging support for legislative carveouts like HR 2771, savvy suppliers can take certain matters into their own hands.  By using the remainder of this year to increase efficiency and diversify payer/product concentrations, suppliers will be positioned to weather the uncertain ramifications for Round 2021.

SOURCE LINKS
https://www.congress.gov/bill/116th-congress/house-bill/2771

The Office of Inspector General (OIG) says it all in the provocative, if not brief, title of its February 2020 report: The Majority of Providers Reviewed Used Medicare Part D Eligibility Verification Transactions for Potentially Inappropriate Purposes.

The OIG reviewed Part D eligibility transactions submitted by 30 different mail-order pharmacies and found that, out of 3.9 million transactions, 2.6 million had no association with a subsequent prescription.

So that’s not good.

The OIG selected the pharmacies based on large volumes of E1 transactions relative to the number of prescriptions ultimately processed. At the time of the audit, 10 of the selected entities were closed or already under investigation. The OIG determined another 15 were using, or hiring others to use, the system for inappropriate purposes.

Perhaps those findings are not surprising given that the sample selection criteria targeted entities with large numbers of requests and proportionately few processed Part D prescriptions. It seems like self-fulfilling prophecy. The more we consider the sampling techniques of these audits, the more skeptical we become of using the findings to support extrapolation and industry-wide application. Nonetheless …

As a result of the audit, expect CMS to:

• Issue clear guidance to providers for the proper use of the system, specifically that it is not a database for marketing purposes and should only be used by entities that dispense prescription medications and submit those prescriptions for insurance reimbursement.
• Closely monitor suppliers with high numbers of eligibility inquiries.

All suppliers should be cautious of clearinghouses, gateways, or data mining software applications that use Part D transactions to scrub large volumes of beneficiary data for purposes other than filling prescription medications.

SOURCE LINKS
https://oig.hhs.gov/oas/reports/region5/51700020.asp