The Connecticut Podiatric Medical Association will continue to update you on resources available to help you and your practice during the novel Coronavirus pandemic.
MESSAGE FROM CPMA
JUNE 16, 2020
Most of us are beginning to slowly return to a more normal level of practice, surgery, and business now that the state is starting a phased-in approach to opening.
Below are the important action items for the coming month.
PPP Flexibility Act
On June 3, 2020, the Senate passed the Paycheck Protection Program Flexibility Act, which amends important terms to the Paycheck Protection Program (PPP). These changes, summarized below, provide improved terms for businesses that are borrowing under this federal relief program.
Some of the highlights of the PPP Flexibility Act that we would like to draw your attention to are:
- The timing to use funds applicable for forgiveness has been extended from an 8-week period to a 24-week period (aka the “covered period”). That means the funds previously expiring June 30, 2020 can now be used until December 31, 2020.
- Previously, 75% of the funds had to be used for payroll costs and only 25% could be used for rent, utilities, and mortgage interest. The new terms reduce the 75% requirement to 60%, providing 40% to be used toward rent, utilities, and mortgage interest. Note that the requirement to use 60% of the funds on payroll is a threshold in order to be eligible for forgiveness.
- Rehiring requirements have been relaxed so borrowers are not penalized if they are unable to find qualified employees or restore business operations to February 15, 2020 levels due to COVID-19 related operating restrictions.
- Businesses that took a PPP loan can now delay payment of their payroll taxes, which was previously prohibited.
- Deferred payment of principal, interest, and fees can now be delayed until up to 10 months after the covered period (such deferment period is based on when the loan forgiveness application is submitted by the borrower and remitted by the SBA).
- New borrowers will have 5 years instead of 2 years to repay loan amounts (for amounts not to be forgiven, if any). Note that the PPP Flexibility Act does not prohibit lenders and borrowers from amending maturity terms for preexisting loans. If you have already obtained a PPP loan, you may want to discuss this term extension with your lender.
The PPP still has funding available, but the ability to apply still closes on June 30, 2020, despite some confusing language in the recent legislation that implies it may be open until the end of the year. Therefore, if you have not previously obtained funding we suggest you contact lenders to apply as soon as possible.
Loan Details and Repayment Process
If you received a PPP loan, you must have first applied through the SBA (Small Business Association). You should have already received a small grant up to $10,000 several weeks ago. Subsequently, the SBA loan department may have contacted you about a loan program where you could borrow up to $150,000. This loan (not a grant) is a 3.75% fixed interest loan that requires no payments for the first year and is then paid back at a fixed monthly amount. The term of the loan is for 30 years with no pre-payment penalty. The catch is that the interest begins accruing right away.
I hope you are safe and well. Look for more help as we continue to reopen our practices and our state.
Marc A. Lederman, DPM
CPMA Executive Director
Paycheck Protection Program
Paycheck Protection Program
The Paycheck Protection Program is a federal program to provide forgivable loans. Banks will begin accepting applications on Friday, April 3rd. The program has a total funding level of $349 billion and is administered by the US Department of Treasury. Small businesses will submit applications to select banks. For more information you can click here.
- Participating banks will accept and process applications.
- Call your bank or use the SBA Lender Match tool.
- Here is a link to the application.
Loan amounts are provided to businesses based on each company's payroll level. For instance, the typical loan amount will be 2.5 times average monthly payroll. During the COVID-19 period, when a company retains employees or rehires them, the principal and interest on loans provided by the program will be forgiven.
Podiatry offices in Connecticut may continue to be open, but the CDC recommends medical offices to discontinue elective procedures (surgical and office-based) and delay all elective ambulatory provider visits.
Health-care facilities and clinicians should prioritize urgent and emergency visits and procedures now and for the coming several weeks. As an example, some offices are seeing patients every 30 minutes and not double booking to minimize patient to patient and patient to staff contact. You may want to notify your patient-base that you are available for emergency visits that can include fractures, sprains, infections, etc. to keep these patients away from hospitals and walk-in facilities.
The Centers for Medicare and Medicaid Services announced major changes to services that podiatrists can furnish remotely allowing podiatrists to submit CPT 99201-99215 when these services are provided remotely. For details click here.
Face Time and Skype may be used for telemedical purposes. HIPPA rules will not apply to telemedicine within reason during this crisis.
Office E&M Coding without modifiers may be used.
For more information on the guidelines for telemedicine, please see comments shared by Dr. David Freedman, APMA Coding Committee, here.
Be sure to check your private insurance carriers for their updates on the use of telemedicine for your practice. Individual carriers may vary in their rules and regulations.
April 8, 2020 | Latest Coding News on Use of Telemedicine
I would like to thank Dr. David Freedman and Dr. Mike Fein for helping with the information.
The following will outline which codes to use and how to bill for your service:
- For Medicare patients ONLY: (not Medicare Advantage) when billing a Telemedicine visit the proper codes are the E&M codes. Your Place of service should be 11 (office). The Place of service (POS) is equal to what it would have been had the service been furnished in-person.
- You will also add the modifier 95, which means that the service rendered was actually performed via Telehealth.
The billed code is based on either time or level of complexity of the call. Your documentation will be as you normally do and the time involved should take into account your time to review relevant medical tests and document properly. CMS has stated the visit is coded based on Medical Decision Making or Time.
The times are as follows:
- 99211 5 minutes
- 99212 10 minutes
- 99213 15 minutes
- 99214 25 minutes
The payments made will be the same as any billed E&M code.
Finally, if you perform a telemedicine call with a Medicare patient but are unable to secure video, and it is audio only, then the only code to use is the G2012, and no modifier is needed.
For non-Medicare insurance companies, you can still use the codes 99441, 99442 and 99443. These codes are based on time and must be with the use of video and were previously outlined. These are patient-initiated services with physicians, the patient is an established patient. These are online digital E/M services and are reported once for the physician's cumulative time devoted to the service during a seven-day period.
99421 Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes
99422 Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes
99423 Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes
It is important for all non-Medicare insurance plans that you check the Insurance company website for their specific coding requirements as there may be some nuances to one particular plan.
Message by Marc Lederman
APMA is frequently updating their Coronavirus (COVID-19) Information. Their FAQs are helpful and updated based on recommendations from the CDC and other governmental sources. Learn more.
Centers for Disease Control (CDC)
Get your practice ready. Learn more.
Information for Healthcare Professionals. Learn more.
The National Telehealth Policy Resource Center
State Telehealth Laws and Reimbursement Policies, Fall 2019. The specific laws regarding Connecticut can be found on pages 71-77. Learn more.