The Waiver is effective retroactively to Medicare claims for services rendered on or after March 1, 2020. That configuration allows fresh air to flow in through the back left window and out through the front right window and helps create a barrier between the driver and the passenger. Such efforts could be necessary if rideshare drivers and TNCs are going to be depended upon to provide essential services at this time. Although drivers for TNCs could be asked to deliver goods to and between medical facilities, they cannot move medical samples or soiled supplies between medical facilities. 2020. p.eabe0166. Why does the "OIG Policy Statement Regarding Application of Certain Administrative Enforcement Authorities Due to Declaration of Coronavirus Disease 2019 (COVID-19) Outbreak in the United States as a National Emergency" not incorporate sections II(B)(12)-(18) of the blanket waivers of the physician self-referral law as issued by the Secretary? When you are in a confined environment, there is a risk of airborne infection, especially in ride-sharing trips that take just 15 to 20 minutes," Mathai tells Verywell. 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. Mathai explains car air ventilation flows from the back to the front window. Under the unique and exigent circumstances resulting from the COVID-19 outbreak, we believe that modest, in-kind transportation assistance (e.g., a voucher or reimbursement for taxi or ridesharing services or a driver or ridesharing service paid for by the practice)-that does not otherwise satisfy the conditions set forth in the existing safe harbor for local transportation-provided for free to established patients of an oncology practice would present a low risk of fraud and abuse under the Federal anti-kickback statute and the Beneficiary Inducements CMP and could improve beneficiaries' access to oncology care in certain circumstances. Under the state protocol, if EMTs are unable to restart the heart or revive an adult cardiac patient using CPR, defibrillators, medication and other techniques at the scene then they are not to transport them to the hospital. In your submission, please provide sufficient facts that allow for an understanding of the key parties and terms of the arrangement at issue. 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. Some hospitals may be in a position to provide certain relief to FQHCLAs by, for example, suspending rent or forgoing the accrual of interest on loans or lines of credit, which could allow FQHCLAs to continue to serve medical needs in underserved communities during the public health emergency. Jocelyn Solis-Moreira is a journalist specializing in health and science news. Mathai says that currently, this study does not apply to other modes of public transportation. Every day you know EMS workers make life and death decisions, and it's in consultation with the hospital physicians emergency room physicians that will make this decision out in the field," said Hahn, "They're gonna make every effort that's reasonable based on you know what the case is all the decisions are based, you know, based on sound clinical judgment.. 149 0 obj <> endobj 2Section 1128B(b) of the Social Security Act (Act), 42 U.S.C. Call 911 if you suddenly have blurry vision, double vision, or loss of vision. That can be a sign of stroke or other serious illness. EMT Ambulance Ride-Alongs. The Office of Inspector General (OIG) recognizes that, in the current public health emergency resulting from the outbreak of the COVID-19, the health care industry must focus on delivering needed patient care.1 As part of OIG's mission to promote economy, efficiency, and effectiveness in HHS programs, we are committed to protecting patients by ensuring that health care providers have the regulatory flexibility necessary to adequately respond to COVID-19 concerns. While the group practice may be able to structure such transportation arrangements to comply with the existing safe harbor for local transportation, 42 C.F.R. Some studies show that the novel coronavirus can live in the air for up to three hours, so leaving your car's windows open between rides for . The eye protection should be put back on when you stop driving and are still with the person with COVID-19. This could include an expanded service into remote, rural areas. Mathai says aerosol droplets are very tiny, and they linger in the air for long durations. Normally the family member or friend will ride in the front cab passenger seat of the ambulance. The mask is there to protect others from other respiratory droplets or anything that is coming out. Sections II(B)(12)-(17) of the blanket waivers of the physician self-referral law protect "referrals," as defined under section 1877(g) of the Act, rather than "remuneration," and reflect differences in the statutory proscriptions of the physician self-referral law when compared to the Federal anti-kickback statute. 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. Because each vehicle is designed differently, a study design would need to be customized to apply to the specific dimensions of the vehicle. For the purpose of these Frequently Asked Questions (FAQs), the original declaration and any renewals are collectively referred to as the "COVID-19 Declaration.". Similarly, depending on the facts and circumstances, providing free goods or services to Federal health care program beneficiaries may implicate the Beneficiary Inducements CMP. If you have to ride in a car with someone who has not been in your household during the . In the unique circumstances resulting from the COVID-19 outbreak, we believe that these scenarios likely would present a low risk of fraud and abuse under the Federal anti-kickback statute and the Beneficiary Inducements CMP provided the services being offered are (i) necessary to meet patient care needs as a result of staffing shortages directly connected to the COVID-19 outbreak; (ii) provided for free or at a reduced cost only when necessary as a result of the COVID-19 outbreak; (iii) limited to the period subject to the COVID-19 Declaration; and (iv) not contingent on referrals for any items or services that may be reimbursable in whole or in part by a Federal health care program, either during or after the COVID-19 Declaration period. 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. Because the facts presented here differ from those in the 1994 Alert and the 2014 Alert, we believe that the proposed arrangement between the clinical laboratory and retail pharmacy, in the context of the COVID-19 public health emergency, would be sufficiently low risk under the following circumstances: (i) the retail pharmacy incurs costs in operating the testing collection sites; (ii) the payment is fair market value for the items and services furnished by the retail pharmacy in running the sites; and (iii) the retail pharmacy is not submitting claims to Federal health care programsor directly or indirectly receiving other Federal or State fundingthat reimburse it, in whole or in part, for the items and services furnished by the retail pharmacy in running the sites for which the laboratory reimburses the pharmacy. As compensation for the enumerated administrative services, each HCP would share a portion of the vaccine administration fees the HCP collects from third-party payors, including Federal health care programs, with the Organization as follows: After the HCP retains a certain amount per hour for the HCP's compensation and to cover the staffing costs associated with the clinicians who administer the vaccine under the HCP's supervision, the HCP would distribute the remaining vaccine administration fee amounts to the Organization. A complex chain of financial pressures affected state ambulance providers during the COVID-19 public health crisis. I know there are people wh." Kari Harbath on Instagram: "Another shoutout to medical professionals: we see you. Former Senior Medic. We recognize the need during the COVID-19 outbreak for many health care providers and suppliers to furnish services through various modalities in lieu of in-person visits. The paramedic or EMT performing CPR is also required to wear personal protective equipment. 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. We also acknowledge that OIG's longstanding guidance makes clear that, depending on the facts and circumstances, providing free or discounted goods or services to an actual or potential referral source may violate the Federal anti-kickback statute. If you're unsure whether or not you can safely drive to a hospital, it is always best to defer to calling an ambulance. For example, the oncology group practice may desire to provide transportation assistance for patient safety reasons to prevent the risk of COVID-19 exposure to patients while using public transportation. The hospital would receive no payment from any (i) independent physician to whom it grants free access to the platform, or (ii) payor for services furnished through its telehealth platform by the independent physicians. Routine waivers of cost-sharing obligations implicate the Federal anti-kickback statute and the civil monetary penalty provision prohibiting inducements to beneficiaries and may result in overutilization or inappropriate utilization of items and services reimbursable by Federal health care programs. 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. We also acknowledge that it may be possible for parties to structure the provision of free or reduced-cost lodging to meet the Promotes Access to Care exception to the Beneficiary Inducements CMP (see, e.g., OIG Advisory Opinion 17-01), 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. While the study focused on passenger cars, it opens doors to other areas of study. 1001.952(bb), we understand that the transportation the oncology group practice would like to provide may not always meet every requirement of this safe harbor; for example, the travel distance between a patient's home and the alternate practice location may exceed the mileage limitations associated with that safe harbor. Please have your government issued ID with you when you report for your ride-along. The Secretary may extend the [public health emergency] declaration for subsequent 90-day periods for as long as the [public health emergency] continues to exist, and may terminate the declaration whenever he determines that the [public health emergency] has ceased to exist." Read our, CDC Recognizes COVID-19 Can Be Airborne: Here's What That Means, Air Flow May Have Caused COVID-19 Spread In a Restaurant, Study Shows, Privacy Concerns Continue To Prevent Contact Tracing App Use. This response addresses only the provision of free COVID-19 testing by the FQHC to Federal health care program beneficiaries. If rideshare drivers are going to continue to work, everyone, from the TNCs to the customers, must ensure this remains a safe occupation.
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