Dear CMS: - HealthSmart MSO



March 15, 2020

BND Providers and MSOs

Re: COVID-19 Preparedness and Contingency Plan

Dear Contracted Medical Groups and Delegated MSOs: 

In response to emergency declarations by the State and Federal government as a result of the Corona Virus, COVID-19, Brand New Day has developed and is implementing a COVID-19 Preparedness & Contingency Plan. The plan includes processes to ensure compliance with the attached regulatory guidance and a contingency plan to address potential employee absenteeism and/or other challenges related to COVID-19. The objective is to ensure ongoing services and care for all members including but not limited to those who are presenting symptoms or have been exposed or infected by the COVID-19 virus.

Teladoc – telephonic member access to a live physician 24/7 at no charge

To help ease the abundance of calls you may receive, please feel free to give information to Brand New Day members regarding “Teladoc,” a service that reaches a live doctor 24 hours a day, 7 days a week. This year-round service is free of charge for Brand New Day members (paid for by Brand New Day). The phone number is 1-888-687-7321, (TTY: 711). There is no limit to the number of calls a member can call.

Regulatory Requirements

To abide by requirements from the Centers for Medicare & Medicaid Services (CMS), the California Department of Managed Health Care (DMHC) and the California Department of Health Care Services (DHCS) Brand New Day and all providers and MSOs are to ensure the following:

Waiving Copayments - COVID-19 Services, Treatment, Tests, Prescriptions

The Plan and providers are to waive copayments for tests, services, and prescriptions related to COVID-19. Please implement:

• “Zero” ($0) co-pays, deductibles, or coinsurance for all medically necessary screening and testing, lab work, office visits, urgent care, emergency department, hospitalization, and prescriptions when the purpose is for screening, testing, treatment, or prescriptions for COVID-19.

• Notify, as expeditiously as possible, contracted providers that Brand New Day is waiving cost-sharing as described above.

Waiving Prior Authorization and Gatekeeper Functions

• Waive in full requirements for gatekeeper referrals (related to COVID-19).

• Waive prior authorization requirements for tests or services related to COVID-19 (with or without declaration of a state of emergency or public health declaration).

• Provide out-of-network (OON) services at “Zero” ($0) copay / coinsurance for COVID-19 screening, testing, and treatment. If charged a copayment/coinsurance Members can submit fills for prompt reimbursement (have Member call 1-866-255-4795 for directions).

• Patients Quarantined in Hospitals – Patients who would have been otherwise discharged from the hospital after an inpatient stay but instead are required to remain in the hospital under quarantine do not have to pay an additional deductible/copay for the quarantine in a hospital.

Timely Access to Care and Services

• Provide COVID-19 related services via telehealth are allowed in any geographic area and from a variety of places including beneficiaries’ homes. (CMS is relaxing the guidance specifying this is only for members in rural areas and the locations where such services can be furnished.)

• Provide “Timely Access to Care” by adequately staffing of telephone lines, answering services, nurse advisors, customer service representatives, physician office visits, and alternate coverage during absences, closures, and after hour services.

• Brand New Day call centers are staffed 24/7 to assist members and/or providers as needed (1-866-255-4795). Please share this number as needed.

New Billing Codes COVID-19

New codes allow providers and labs to bill for the specific COVID-19 tests instead of using an unspecified code, which means better tracking of the public health response for this particular strain of the coronavirus to help protect people from the spread of this infectious disease.

• HCPCS Code U0001 – for Providers to bill for the CDC 2019 Novel Coronavirus Real Time RT-PCR Diagnostic Test Panel

• HCPCS Code U0002 – for Laboratories and healthcare facilities to bill Plans (or Medicare if member is under Original Medicare).

Billing Codes – Telehealth & Other Communication-Based Technology Services

Virtual Check-Ins – are allowed for patients to connect with their doctors without going to the doctor’s office, patients who have an established relationship with a physician or certain practitioners and when communication is not related to a medical visit within the previous 7 days and does not lead to a medical visit within the next 24 hours (or soonest appointment available). Patient consent must be obtained and documented in the medical record prior to the patient using the service.

• HCPCS Code G2012 – for virtual check-in services furnished through several communication technology modalities, such as telephone

• HPCPS Code G2010 – for virtual check-in services including captured video or image

Communication via Patient Portals – Medicare also allows patients to communicate with their doctors without going to the doctor’s office, by instead using online patient portals. The communications must be initiated by the member and can occur over a 7-day period. (Providers may educate beneficiaries regarding the availability of this kind of service prior to the patient initiation.) Such services may be billed using the following codes:

• CPT Codes 99421-99423 as applicable

• HCPCS codes G2016-G206 as applicable

Prescriptions

• Prescriptions – “Zero” ($0) copay for COVID-19 drugs when they become available

• Prescriptions - Brand New Day has relaxed “Refill-Too-Soon” restrictions to ensure Part D drugs are provided at the point of sale including allowing Members to obtain the maximum extended day supply if requested and available.

• Prescriptions – In the event of a shortage of a prescription drug, Brand New Day is waiving prior authorization and/or step therapy requirements if the prescriber recommends a different drug due to a shortage.

• Prescriptions – If a member fills a prescription out-of-network (non-contracting pharmacy) the member can obtain a reimbursement for any copayment charged (have Member call 1-866-255-4795 for directions).

• Prescriptions – BND is encouraging the use of home or mail delivery of prescriptions. Member may call 1-866-255-4795 for detailed information.

Vaccines

Under current law, if a vaccine becomes available for COVID-19, Medicare will cover the vaccine. All Part D plans will be required to cover the vaccine if it is a Part D drug.

Website Requirements

• Prominently display on the plan’s public website a statement that the plan is waiving cost-sharing for medically necessary screening and testing for COVID-19. This is being implemented as soon as possible.

Business Continuity Plans

As required under 42 CFR 422.504 (o) and 423.505(p), Medicare Advantage Organizations must have business continuity plans to ensure restoration of business operations following disruptions, including emergencies (such as the COVID-19 pandemic). It is equally important, if not more important, for providers to have similar plans. If you have suggestions to improve the Brand New Day Plan, as it related to the COVID-19 virus, please send input to Compliance@. If you need help in developing a continuity plan, please also contact us at the email address above.

Should you have any questions, please contact your Provider Relations Representative (PRR), or Delegation@. If you wish to speak with someone by telephone, please contact the Compliance Officer at (562) 310-6868. We value the good care and services you provide to Brand New Day Members. We wish good health to you, your staff, and your patients.

Respectfully,

Venessa Harewood

Venessa Harewood

Director of Provider Relations

cc:

← Jeff Davis, Brand New Day CEO

← Connie Snyder, Compliance Officer

← Thai Du, Brand New Day Manager of Delegation Oversight

Enclosure/s:

← Department of Managed Health Care (DMHC) All Plan Letter (APL) 20-006

← Department of Health Care Services (DHCS) COVID-19 Memo to MCPs

← Centers for Medicare and Medicaid Services (CMS) Health Plan Management System (HPMS) Memo: Information Related to Coronavirus Disease 2019-COVID-19

← Centers for Disease Control ICD-10-CM Official Coding Guidelines- Supplement Coding Encounters Related to COVID-19 Coronavirus Outbreak (coding for COVID-19 related testing and screening)

Reference links:

← Guidance on testing, screening, and notification of positive results can be found on the Centers for Disease Control and Prevention (CDC) and county departments of public health.

← Specific guidance for Healthcare Professionals can be found on the CDC website at - ;

← DPH -

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