On March 10, 2020, the Centers for Medicare & Medicaid Services (“CMS”) supplemented the guidance that we previously discussed in our March 6, 2020 blog post in order to provide additional guidance to healthcare providers, specifically home health agencies and dialysis facilities, in addressing the spread of the 2019 Novel Coronavirus (“COVID-19”).

The new memoranda for home health agencies and dialysis facilities are intended to offer clear, actionable information for healthcare providers on the treatment, screening and transfer of patients in light of the COVID-19 outbreak. The guidance enhances health and safety requirements and aims to help control and stop the spread of COVID-19. Among other recommendations, the guidance advises Medicare-enrolled dialysis facilities to identify high risk individuals prior to appointments or upon arrival and screen them for fever and symptoms of respiratory infection, international travel to restricted countries in the past 14 days, and contact with persons known or suspected of having contracted COVID-19. The guidance further recommends the screening of visitors and staff for potential exposure.

The guidance is similar to the recommendations made to home health agencies by the Centers for Disease Control and Prevention (“CDC”). However, the guidance from CMS also addresses issues such as when it is safe to treat patients at home, when patients should be considered for hospitalization and recommendations for family member exposure when providing care to patients known or suspected of having COVID-19. CMS recommends that home health agencies remain vigilant in monitoring patients for symptoms of COVID-19. The guidance concludes with a frequently asked question section offering additional information to promote patient and provider safety in light of COVID-19.

We will continue to monitor CMS’s response to COVID-19 and its impact on healthcare providers that participate in the Medicare program.