The federal government continues to evolve the requirements for how hospitals should deal with the COVID-19 pandemic. Last month, it finalized two significant new rules that impose regulatory hurdles for hospitals seeking desperately needed financial assistance from federal programs, including enhanced payments under the Medicare program. A hospital's failure to implement these new rules threatens eligibility for much-needed enhanced payments, or worse, government fraud actions to recoup reimbursement already received.

Scrutiny of Enhanced Payments for COVID-19 Inpatient Discharges

As part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, hospitals paid under the Inpatient Prospective Payment System, long-term care hospitals, and inpatient rehabilitation facilities are entitled to receive a 20% increase in reimbursement for treatment of a Medicare patient diagnosed with COVID-19 who is discharged during the COVID-19 public health emergency period. These enhanced payments provide critical support to hospitals by helping offset the higher cost of treating COVID-19 patients, including the purchase of necessary supplies and equipment such as personal protective equipment (PPE) and ventilators. The CARES Act does not address documentation requirements to qualify for the 20% funding boost, and initial guidance suggested that documentation that an individual has COVID-19 would suffice.