Can a provider or supplier such as a hospital, pharmacy, or health system provide other providers and suppliers with free items and services related to COVID-19 vaccine storage, distribution, redistribution, and/or administration? Pilot programs allowing medication pickup by rideshares are underway, supplementing existing efforts by Doordash, Postmates, and Deliv. Nevertheless, we believe that the provision of space at no charge by an FQHC in a rural area for a pharmacy to administer COVID-19 vaccinations would pose a low risk of fraud and abuse under the Federal anti-kickback statute because of the unique circumstances of the COVID-19 public health emergency and could address challenges in vaccine access for individuals in rural areas. Commentary gives RAND researchers a platform to convey insights based on their professional expertise and often on their peer-reviewed research and analysis. In addition, we recognize that this scenario also involves potential direct or indirect financial relationships between the non-governmental donor entity providing funding, the FQHC, and Federal health care program beneficiaries, and there are different potential fraud and abuse risks with respect to those relationships. A Day With a Paramedic Fighting the Coronavirus Outbreak | TIME Ph.D. Student, Pardee RAND Graduate School, and Assistant Policy Researcher, RAND, A rideshare driver wears gloves and a mask while driving following the outbreak of COVID-19, in New York City, March 15, 2020, by Laura Fraade-Blanar and Christopher M. Whaley. 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. An OIG advisory opinion is legally binding on HHS and the requesting party or parties. Ambulances are being told not to transport trauma patients - victims of heart attacks, gunshot wounds, car crashes - to the hospital if they can't be resuscitated in the field. 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. 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. When she came home, a letter arrived: The air ambulance company said she owed $52,112 for the trip. If you wish to provide feedback, please contact Patient Experience and Consumer Participation Department either via patientexperience@ambulance.vic.gov.au or call 1800 875 137. 1001.952(bb); and (vii) the provision of the Telecommunications Technologies is limited to the time period subject to the COVID-19 Declaration, requiring the return of the cell phone, cessation of payment for the patient's service or data plan, or both, after the time period subject to the COVID-19 Declaration. COVID-19 Spread and Ride-sharing - Health on the guidance repository, except to establish historical facts. Felt like a steamroller was squeezing my lungs 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. Ambulance companies hit hard by COVID costs - ajc It is our understanding that many FQHCLAs and other providers face financial strain in light of the COVID-19 public health emergency due to shifting demands for health care items and services and, consequently, decreased revenue. We welcome your comments as they assist us to improve our services. Not only is it dangerous to drive yourself to a hospital when you're experiencing these symptoms, but it will also take extra time that can prevent you from getting the care you need as soon as you need it. "Ambulance officers across the country have been directed to only transport family members with patients in exceptional circumstances. 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. 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. The eye protection should be put back on when you stop driving and are still with the person with COVID-19. 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. Beyond current services, TNCs deliver customer-purchased groceries and goods. More widespread availability of rideshare for NEMT may save lives, reserve emergency resources for those who need them, and provide safe pathways to primary care for the chronically ill. Check the latest closings and delays for schools, business, and churches around the Hudson Valley. People are sick, losing jobs, postponing important life events, projects, losing chunks of their retirement, and living in a constant state of fear. Mathai and his team are looking at applying similar simulations to improving airflow in other confined spaces, from helicopters to restaurants. 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. This remuneration also could reasonably influence a patient to select the group practice to receive federally reimbursable items and services. Soon after the May 2018 incident, Brasfield, now 39, got a $1,206 bill for the 4-mile. That can be a sign of stroke or other serious illness. A complex chain of financial pressures affected state ambulance providers during the COVID-19 public health crisis. While the study focused on passenger cars, it opens doors to other areas of study. Documentation to support medical necessity and the qualifying communitywide EMS protocols must be maintained by the ambulance providers and suppliers and provided to CMS contractors, such as part of a medical review, upon request. The school nurse checked Brasfield's pulse, found it too fast to count and called 911 for an ambulance. Patients and physicians would be able to access COVID-19 antibody testing results through the laboratory's patient portal, and the results from the antibody testing program also would be reported to the Centers for Disease Control and Prevention and State public health agencies to further support COVID-19 surveillance and response efforts. Rental charges paid by a physician (or an immediate family member of a physician) to an entity that are below fair market value for the physician's (or immediate family member's) lease of office space from the entity. COVID can worsen quickly at home. Protect yourself when using transportation. Can an oncology practice offer free or discounted lodging to its financially needy patients who are Federal health care program beneficiaries if, prior to the COVID-19 public health emergency, such patients would have had access to free or discounted housing at a nonprofit lodging facility while receiving chemotherapy or radiation treatment? 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). Door-to-door service involving light assistance from the driver is being explored under other new pilots. While any type of traveling can increase your chances of COVID-19 exposure, riding in a car is especially risky because passengers are in a confined space. However, we believe that there are scenarios in which an HHA and an assisted living facility could work together to fill critical gaps caused by the COVID-19 outbreak to provide necessary health care services to vulnerable beneficiaries residing in an assisted living facility. 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. Packed Hospitals Struggle to Handle Non-COVID Patients - US News During the current pandemic, movement has slowed as people shelter in place. We recognize that this scenario also involves potential direct or indirect financial relationships between the private foundation, the FQHC, and the Federal health care program beneficiary receiving the grant funding, and that there are different fraud and abuse risks with respect to each relationship. 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. 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. Our website is not intended to be a substitute for professional medical advice, diagnosis, or treatment. Accordingly, under the unique circumstances of the COVID-19 public health emergency, and in the context of the Waiver cited above, OIG believes it would represent a sufficiently low risk of fraud and abuse for ground ambulance providers and suppliers to waive or discount beneficiary cost sharing obligations for claims billed in accordance with the Waiver. The informal feedback here applies only to arrangements in existence solely during the time period subject to the COVID-19 Declaration. Can the FQHC furnish cash-equivalent gift cards, in specified amounts, to address social determinants of health for financially needy individuals, including Federal health care program beneficiaries who meet certain criteria? 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. Can health care providers and practitioners furnish services, not to exceed their scope of practice, for free or at a reduced rate, to assist skilled nursing facilities (SNFs) or other long-term-care providers that are facing staffing shortages due to the COVID-19 outbreak? 200 Independence Avenue, S.W. Instead, open windows that are farthest from you. Emergency Medicine Author has 946 answers and 1.6M answer views Updated 3 y. Under its agreements with HCPs, the Organization would provide the following administrative services: arranging for the physical vaccination sites, data systems, online and web-based scheduling, site development and training, and reporting to state agencies. In light of these EMS protocols, on May 5, 2021, pursuant to section 1135(b)(9) of the Social Security Act, the Secretary of Health and Human Services waived certain statutory requirements relating to Medicare payments for ground ambulance services furnished in response to a 911 call (or the equivalent in areas without a 911 call system) in cases in which an individual would have been transported to a destination permitted under Medicare regulations but such transport did not occur as a result of communitywide EMS protocols established due to the public health emergency (the Waiver). 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. 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. Driving vs Public Transit vs Ride Sharing During Coronavirus - WebMD