Tim Gruber for The New York Times When Congress passed a law. The AAA, PWW and other ambulance industry partners have also requested that CMS relax the ambulance medical necessity rules during the public health emergency. At least three states removed regulatory barriers to allow rideshares to provide NEMT in the last few weeks, some using the 1135 waivers (PDF) under the Stafford Act to exercise greater flexibility. They also recently started delivering groceries, medical supplies, and necessary goods to medically vulnerable or transportation-disadvantaged recipients on behalf of nonprofits, government agencies, and health care organizations. Check the latest closings and delays for schools, business, and churches around the Hudson Valley. Making ridesharing a workable option in the current crisis requires local and state government cooperation, TNC capacity, clarity around the rideshare driver's role, and protection for the driver. James received a Master of Library Science degree from Dominican University. . To complete an EMT basic course at the California Institute of Emergency Medical Training (CIEMT), you must perform ambulance ride-alongs. Washington, D.C. 20201 For example, under some State plans certain providers and suppliers assume responsibility for storing COVID-19 vaccines in cold or ultracold storage and redistributing (which includes, in certain instances, transporting) vaccines to other providers and suppliers, some of which may be actual or potential referral sources. We understand that Federal health care program beneficiaries with cancer, who are receiving chemotherapy or radiation treatment, sometimes qualify for free or discounted housing at a nonprofit lodging facility near treatment sites while receiving treatment. EMT Ambulance Ride-Alongs. In addition, no party may bill or otherwise shift the costs of free blood draws to Federal health care programs. 1001.952(b). However, under the facts described herein, the payment of compensation by HCPs to the Organization in the form of a share of vaccine administration fees paid by third-party payors, including Federal health care programs, presents a sufficiently low risk of fraud and abuse under the Federal anti-kickback statute because of the unique circumstances of the COVID-19 public health emergency, the low risk of overutilization, and the safeguards incorporated into the arrangement, as described above. The Centers for Disease Control and Prevention (CDC) also recommends that people with COVID-19 avoid public transportation, ride-sharing, or taxis. Given the numerous potential variations on the facts related to donors, this response focuses only on the financial relationship between the provider and patient. OIG has longstanding and continuing concerns regarding the provision of cash or cash equivalents to Federal health care program beneficiaries. Therefore, a retroactive waiver of cost-sharing obligations by ground ambulance providers and suppliers for instances in which no ambulance transport was provided but for which the Medicare program retroactively reimburses for these specified services is unlikely to induce the use of those or any other services in the future. Patients need to be advised that if they have confirmed or suspected COVID-19 and are seeking help or are experiencing a medical emergency, rideshares are not the right transportation option. Emergency Medicine Author has 946 answers and 1.6M answer views Updated 3 y. incorporated into a contract. The FQHC would not bill the COVID-19 testing to any Federal health care program, other third-party payors, or the patient. Patients who. Thank you. On the fence about calling an Uber to get to an appointment? Mathai says aerosol droplets are very tiny, and they linger in the air for long durations. Learn More. The informal feedback here applies only to arrangements in existence solely during the time period subject to the COVID-19 Declaration. They looked at the differences in air flow when specific windows were open versus when all of the windows were open versus being closed. If rideshare drivers are going to continue to work, everyone, from the TNCs to the customers, must ensure this remains a safe occupation. Please have your government issued ID with you when you report for your ride-along. A lot of the spread is from places where we dont necessarily know where the transmission took place, he says. An OIG advisory opinion is legally binding on HHS and the requesting party or parties. The site is secure. In earlier FAQs, we have recognized that FQHCs deliver care to some of the nation's most vulnerable individuals and families, which can include Federal health care program beneficiaries. Nevertheless, OIG believes that a hospital's suspension of rental charges and accrual of interest for a FQHCLA presents a sufficiently low risk of fraud and abuse so long as the following conditions are met: (i) the arrangement suspending rental charges and accrual of interest is set out in a written document or documents, signed by the parties, that describes all material terms of the arrangement (which could be in the form of amendments to the underlying lease and line-of-credit agreements); (ii) the suspension of rent and accrual of interest is not conditioned on the volume or value of Federal health care program business generated between the hospital and the FQHCLA; (iii) the arrangement does not require the FQHCLA (or its affiliated health care professionals) to refer patients to a particular individual or entity or restrict the FQHCLA (or its affiliated health care professionals) from referring patients to any individual or entity; (iv) the suspension of rent and accrual of interest is only offered to the FQHCLA when necessary as a result of the COVID-19 outbreak; and (v) the suspension of rent and accrual of interest is effective only during the period subject to the COVID-19 Declaration. Mathai says that currently, this study does not apply to other modes of public transportation. The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely. In addition, for the transportation assistance to present a low risk of fraud and abuse, the eligible entity must not: (i) determine an established patient's eligibility for transportation assistance in a manner related to the past or anticipated volume or value of Federal health care program business; (ii) publicly market or advertise the in-kind transportation or allow marketing of health care items and services during the course of the transportation or at any time by drivers who provide the transportation; or (iii) pay drivers or others arranging for the transportation on a per-beneficiary-transported basis. OIG expresses no opinion with respect to the application of any other Federal, State, or local statute, rule, regulation, ordinance, or other law that may be applicable to the question answered, including, without limitation, the physician self-referral law, section 1877 of the Act (or that provision's application to the Medicaid program at section 1903(s) of the Act). Can mental health and substance use disorder providers accept donations from public entities (i.e., local, State, or Federal government entities), private charitable foundations, or health plans to fund cell phones, service or data plans, or both for patients who are financially needy or who do not own their own cell phone for the purpose of furnishing medically necessary services while in-person care is disrupted during the COVID-19 outbreak? For highly vulnerable populations, like older adults living independently, using public transportation-NEMT involves either risking potential infection to travel to the places they need to go, or possibly risking other adverse health outcomes by not traveling to necessary medical care. Reduced transportation options create almost impossible dilemmas. The school nurse checked Brasfield's pulse, found it too fast to count and called 911 for an ambulance. /content/admin/rand-header/jcr:content/par/header/reports, /content/admin/rand-header/jcr:content/par/header/blogPosts, /content/admin/rand-header/jcr:content/par/header/multimedia, /content/admin/rand-header/jcr:content/par/header/caseStudies, Don't Be Fooled by China's Mask Diplomacy, Leading with the Proper Use of Scientific Evidence Is Better Than Hiding Behind It, Solving the Mental Health Crisis: Tackling Psychiatric Bed Shortages in California, Great-Power Competition Outside the Indo-Pacific and Europe, The Problems Facing VA Modernization Are Bigger Than Its Software Systems, Violence in Sudan, Alcohol Use, North Korea: RAND Weekly Recap, Russian Military Operations in Ukraine in 2022 and the Year Ahead. As such, and except as provided in the last paragraph below, OIG would not take enforcement action against a provider or supplier that furnishes free or discounted goods or services related to COVID-19 vaccine storage, distribution, redistribution, and/or administration. Can a non-provider philanthropic entity contract to provide certain administrative services to a health care provider relating to the operation of COVID-19 vaccination sites and be compensated on a per-vaccine basis? Providing free testing to individuals who are not Federal health care program beneficiaries would be unlikely to implicate the Federal anti-kickback statute or Beneficiary Inducements CMP. We also acknowledge that it may be possible for parties to structure a program to meet the Promotes Access to Care exception to the Beneficiary Inducements CMP (see, e.g., OIG Advisory Opinion 19-02), but we are unable to make this determination without all the relevant facts, and we further note that there is no parallel safe harbor for protection under the Federal anti-kickback statute. OIG has become aware that some ambulance providers and suppliers may wish to waive or discount beneficiary cost-sharing obligations in the context of services provided and billed to Medicare under the flexibilities provided by the Waiver. In a simulation of two people in a car, the results suggest that better air circulation and less exposure to airborne contaminants were most effective when the passenger sat in the back of the vehicle. Still, people have to obtain non-emergency but necessary medical care, including kidney dialysis, chemotherapy, and prenatal care visits. Study: Temperature and Humidity May Indicate COVID-19 Transmission Risk, Evusheld No Longer Authorized to Prevent COVID. The protocol is intended to protect EMS workers and to limit the number of people that could potentially be exposed by a possibly infected person. During the closure, the group practice desires to provide established patients with modest transportation assistance (e.g., a voucher or reimbursement for taxi or ridesharing services or a driver or ridesharing service paid for by the practice) to assist them in obtaining oncology care at one of the group practice's alternate locations. Door-to-door service involving light assistance from the driver is being explored under other new pilots. Soon after the May 2018 incident, Brasfield, now 39, got a $1,206 bill for the 4-mile. However, under the facts presented to us, the COVID-19 relief grant was specifically designated for emergency cash assistance to individuals and, in the limited context of the COVID-19 public health emergency and with the combination of safeguards presented below, distributing the grant funds to individuals including Federal health care program beneficiaries in the form of cash-equivalent gift cards would be sufficiently low risk. We recognize that effective and expeditious vaccine distribution, redistribution, and administration is crucial to the COVID-19 pandemic response. Tweet. According to the facts presented, the retail pharmacy would set up COVID-19 testing collection sites and would incur certain costs associated with running these sites (e.g., personal protective equipment for employees, scheduling services, processing and sending the specimens). That can be a sign of stroke or other serious illness. Medical necessity for COVID-19 patients. A Look at the Research, Protect yourself when using transportation, Airflows inside passenger cars and implications for airborne disease transmission. How Long Is COVID-19 Contagious? During the COVID-19 public health emergency, some patients who receive care from FQHCs may be experiencing additional financial hardships. Both offer financial assistance to drivers self-quarantining with a doctor's note. It's a risk based decision, said Hahn. The letter from the ambulance. For this reason, Banerjee warns that a passenger not taking proper precautions can potentially lead to community spread, which is dangerous because of the difficulty to contact trace. Can a federally qualified health center (FQHC) with a location in a rural area provide free space to a retail pharmacy that administers COVID-19 vaccinations to FQHC patients and the general public (including Federal health care program beneficiaries)? According to the facts presented, an oncology group practice has temporarily closed a particular office due to actual or potential patient and staff exposure to COVID-19. Finally, making rideshare-based NEMT a workable option requires a firm understanding of what rideshare drivers and TNCs can and cannot do. It is unlikely that such a provider or supplier would have the requisite intent to induce or reward patient referrals, or generate Federal health care program business, by furnishing such goods or services. When Can I Use Public Transportation Again After Being Fully Vaccinated? The HCPs would oversee administration of the COVID-19 vaccine and provide certain clinical staffing to administer the vaccine at the sites. The most surprising finding was that if one occupant could potentially infect the other, opening the window next to you might not necessarily be the best option, Mathai says. ", 1The Secretary of the Department of Health and Human Services (HHS) determined, through a January 31, 2020, determination, pursuant to section 319 of the Public Health Service Act, that a public health emergency exists and has existed since January 27, 2020. It may also save livelihoods, providing employment in a time of economic hardship. However, given the unique circumstances of the COVID-19 public health emergency, we believe that the provision of free or reduced-cost masks would pose a low risk of fraud and abuse under the Federal anti-kickback statute provided that (1) the decision to furnish masks for free or at a reduced cost is directly connected to addressing the impact of the COVID-19 outbreak (e.g., the nursing home needs masks due to COVID-19 supply chain disruptions); (2) the masks are furnished only during the time period subject to the COVID-19 Declaration; (3) the provision of free or reduced-cost masks is not marketed by the physician group; and (4) the provision of the masks is not made contingent on the nursing home's referrals to the physician group of any specified item or service, or any specified volume or value of past or anticipated referrals of items or services that may be reimbursable, in whole or in part, by a Federal health care program. In addition to the facts presented, we also believe that many urban beneficiaries who normally use public transportation (e.g., bus or subway) to access oncology care may temporarily need modest transportation assistance during the COVID-19 Declaration. Parties must separately assess any fraud and abuse risks that may arise with respect to any direct or indirect financial relationships between the donor and the FQHC or Federal health care program beneficiaries. We believe that transportation assistance provided by these categories of providers in accordance with the conditions set forth above also would likely present a low risk of fraud and abuse. Verywell Health's content is for informational and educational purposes only. You must choose from several ambulance companies that CIEMT is contracted with (see list below) to perform these ride-alongs. However, under other circumstances, arrangements between the donor and the provider, or indirect financial relationships between the donor and the patient, could implicateand present risk underthe Federal fraud and abuse laws. We recognize that effective and expeditious vaccine administration is crucial to the COVID-19 pandemic response and that individuals in rural areas may face heightened challenges in accessing vaccines. The eye protection should be put back on when you stop driving and are still with the person with COVID-19. As with many underlying conditions, COVID-19 appears to pose an extra risk for people with kidney failure and patients undergoing dialysis, said Dr. Alan Kliger, a nephrologist at Yale. Babies and children younger than 2 years old Anyone who has trouble breathing or is unconscious Anyone who is incapacitated or otherwise unable to remove the mask without help Masks are meant to protect other people in case the wearer is unknowingly infected but does not have symptoms. Given the numerous potential variations on the facts related to donors, this response focuses only on the financial relationship between the FQHC and the Federal health care program beneficiary receiving grant funding. If you have to ride in a car with someone who has not been in your household during the . endstream endobj 150 0 obj <. Nonetheless, in the unique and exigent circumstances resulting from the COVID-19 outbreak, we believe that free access to a hospital's telehealth platform by physicians on its medical staff would present a low risk of fraud and abuse under the Federal anti-kickback statute and could improve beneficiaries' access to telehealth services, so long as the platform is (i) provided for free to physicians to furnish medically necessary telehealth services; (ii) provided only when necessary as a result of the COVID-19 outbreak and during the period subject to the COVID-19 Declaration; (iii) not conditioned on the physician's past or anticipated volume or value of referrals to, or other business generated for, the hospital for any items or services that may be reimbursable in whole or in part by a Federal health care program; and (iv) offered to all physicians on the medical staff on an equal basis (but not necessarily accepted by every member to whom it is offered). The mask is there to protect others from other respiratory droplets or anything that is coming out. An OIG advisory opinion is a legal opinion issued by OIG to one or more requesting parties about the application of the OIG's fraud and abuse authorities to the party's existing or proposed business arrangement. In addition, individuals would be screened for eligibility after being referred to the FQHC for case management services, but the offer or provision of gift cards would not be conditioned on the individual's past or anticipated future use of the FQHC's services reimbursable in whole or in part by Federal health care programs. When she came home, a letter arrived: The air ambulance company said she owed $52,112 for the trip. The laboratory's stated purpose for the arrangement is to increase patient awareness of antibodies to promote donations of COVID-19 blood plasma, which could be used for certain experimental convalescent plasma therapy treatments for COVID-19.
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