COVID-19 provision of care in alternative settings and hospital capacity

The California Department of Health Care Services (DHCS) has issued guidance regarding several waivers in effect because of COVID-19.  Inpatient facilities can be fully reimbursed for services provided in an unlicensed facility (during an emergency evacuation or because of other need to relocate residents) provided that the California Department of Public Health makes a reasonable assessment that the facility meets minimum standards.

The three day prior hospitalization for coverage of a skilled nursing facility stay is waived for people who need to be transferred because of a disaster or emergency.

The limit of 25 beds and 96 hour stays for Critical Access Hospitals is waived.

Acute care hospitals can house acute care inpatients in excluded distinct part units if the distinct part unit’s bends are appropriate for acute care inpatients.

Acute care hospitals can relocate inpatients from an excluded distinct part psychiatric unit to an acute care bed and unit.

Acute care hospitals can relocate inpatients from an excluded distinct part inpatient rehabilitation unit to an acute care bed and unit.

Ambulance transportation may include any destination that is able to provide treatment in a manner consistent with state and local Emergency Medical Systems protocols.  (DHCS notice, April 22, 2020.)

COVID-19 off-label and/or investigational drugs

The California Department of Health Care Services (DHCS) will cover and reimburse for Fee-for-Service Medi-Cal beneficiaries off-label and/or investigational drugs for use in COVID-19.  A Treatment Authorization Request (TAR) or Service Authorization Request (SAR) is not required.

FDA-approved drugs being used off label to treat COVID-19 must either be used as part of a registered clinical trial, or the treating physician must put appropriate documentation in the medical record.  Non-FDA-approved drugs must be used as part of a registered clinical trial or be used in accordance with the FDA’s Expanded Access pathway (sometimes called compassionate use).

Because of its need for other uses, DHCS is limiting Hydoxychloroquinine to 120 tablets per prescription and Chloroquinine to 60 tablets per prescription.  If a beneficiary needs a larger quantity, a TAR or SAR establishing medical necessity will be required.  (DHCS notice, April 3, 2020.)

COVID-19 CCS MTP guidance

The California Department of Health Care Services (DHCS) has provided temporary direction regarding California Children’s Services (CCS) Medical Therapy Programs (MTP) because of COVID-19.  CCS MTPs can provide physical and occupational therapy services in non-school settings.  County CCS MTPs should implement telehealth methods to allow therapists to provide remove consultation and treatment for routine therapy and equipment needs.

Prior authorization requirements for physical therapy and occupational therapy are temporarily suspended.  However, Treatment Authorization Requests and Service Authorization Requests are still required.  Providers are instructed to state “Patient impacted by COVID-19” in the TAR or SAR.  Providers must still provide supporting documentation of medical necessity.

MTCs should be held remotely instead of face-to-face conferences.  Prescriptions for durable medical equipment that expire during the COVID-19 state of emergency can be extended without a face-to-face meeting with the physician.  (DHCS notice, April 23, 2020, revised April 29, 2020.)

COVID-19 well-child visits

The California Department of Health Care Services (DHCS) suggests that well-child care should be done in person when possible.  Where community circumstances requiring limiting in-person visits, clinicians are encouraged to prioritize in-person newborn care, and well visits and immunizations of infants and young children through 24 months of age when possible.  DHCS encourages providers to discuss with beneficiaries/parent caregivers attending well-child visits in person to receive necessary immunizations and screenings, and providing other services by telehealth.

Med-Cal policies allow providers to provide medical care by telehealth or telephone.  Providers should inform beneficiaries/parent caregivers of the option to have some elements of well-child visits completed via telehealth and explain that some parts of the physical exam and/or immunization must be done in person.  (DHCS notice, April 24, 2020.)

COVID-19 CHDP Gateway enrollment

The Child Health and Disability Program (CHDP) provides health assessments for early detection and prevention of disease and disabilities for low-income children and youth.  The CHDP Gateway is an automated pre-enrollment process for children who are not on Medi-Cal to enroll in Medi-Cal.  The Department of Health Care Services (DHCS) has authorized telephonic signatures for CHDP Gateway applications.  If the individual is not at the provider’s office and not experiencing an urgent health event which requires immediate care, the individual can apply for Medi-Cal online using the Covered California portal.  (DHCS notice, April 17, 2020.)

COVID-19 Medi-Cal Presumptive Eligibility for Breast and Cervical Cancer Treatment Program

The California Department of Health Care Services (DHCS) is allowing telephonic signatures Every Woman Counts and Family Planning, Access, Care and Treatment program providers enrolling individuals for Breast and Cervical Cancer Treatment Program.  A copy of the final pathology report with the qualifying diagnosis must be submitted.  (DHCS notice, April 17, 2020.)