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DHS COVID-19 PROVIDER RESOURCES // OMAP

Medical Assistance Bulletin 09-20-05, 10-20-02, 14-20-01, 31-20-05, 33-20-03: Home Health Services, Medical Supplies, Equipment and Appliances Prescribed by Nonphysician Practitioners

Effective: March 1, 2020; Issued: May 1, 2020

Important Reminder: All providers must revalidate the Medical Assistance (MA) enrollment of each service location every five years. Providers should log into PROMISe™ to check the revalidation dates of each service location and submit revalidation applications at least 60 days prior to the revalidation dates. Enrollment (revalidation) applications may be found at https://www.dhs.pa.gov/providers/Providers/Pages/PROMISeEnrollment.aspx

Purpose

The purpose of this bulletin is to advise providers that certain non-physician practitioners may prescribe home health services, medical supplies, equipment and appliances, effective with dates of service on and after March 1, 2020.

Scope

This bulletin applies to physicians, physician assistants (PA), certified registered nurse practitioners (CRNPS), certified nurse midwives (CNM), podiatrists who render services to beneficiaries in the MA Fee-for-Service and managed care delivery systems. Providers who render services in the managed care delivery system should address any questions with the applicable MA Managed Care Organization. 

Background

On March 6, 2020, Governor Tom Wolf issued a public health emergency declaration in response to the presence of COVID-19 in Pennsylvania. On January 31, 2020, a national public health emergency was declared. On March 13, 2020, COVID-19 was declared a nationwide emergency under the Stafford Act retroactive to March 1, 2020. 

Discussion

The Centers for Medicare & Medicaid Services (CMS) issued the interim final rule (IFR), “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID–19 Public Health Emergency”, on April 6, 2020. 85 Fed. Reg. 19230 (Apr. 6, 2020). The IFR, in part, amends federal Medicaid regulations related to home health services in an effort to:

    • Expand the workforce and continue CMS’ efforts to align Medicaid with Medicare rules for who can order medical supplies, equipment, and appliances, and therapeutic services;
    • Allow smoother access to services for Medicaid beneficiaries, including those who are dually eligible for Medicare and Medicaid; and
    • Eliminate administrative burden to states and providers when dealing with inconsistencies between the Medicare and Medicaid programs.   

The IFR amends 42 CFR § 440.70 to allow licensed practitioners practicing within their scope of practice, such as, but not limited to, nurse practitioners and physician assistants, to order Medicaid home health services during the existence of the national public health emergency for the COVID–19 pandemic. 

Procedure

Effective with dates of service on and after March 1, 2020, PAs, CRNPs, CNMs and podiatrists may prescribe home health services in Pennsylvania’s MA Program. Home health services are comprised of nursing services, home health aide services, physical therapy, occupational therapy, speech pathology and audiology services, as well as, medical supplies, equipment and appliances. 

The IFR authorizes the amendment to 42 CFR § 440.79 until the end of the national public health emergency. The Department may re-issue these guidelines as appropriate. 

Information on MA Program coverage related to COVID-19, to include an FAQ document, can be found on the Department of Human Services website here

The Pennsylvania Department of Health has a dedicated page for COVID-19 that provides regular updates. Click here for the most up to date information regarding COVID-19. 

Comments and Questions

 The appropriate toll-free number for your provider type. Visit the Office of Medical Assistance Programs website at https://www.dhs.pa.gov/providers/Providers/Pages/Health%20Care%