Waivers for Time Studies During COVID-19 Public Health Emergency Ending
At the onset of the pandemic, the federal government took steps to help relieve healthcare providers of many administrative and regulatory burdens. On January 27, 2020, the COVID-19 Public Health Emergency went into action. Now that the pandemic has passed the acute phase, the PHE is set to expire on May 11, 2023, as announced by Secretary of Health and Human Services Xavier Bacerra, on February 9, 2023.
When it comes to time studies, the PHE expiration could have a significant impact on healthcare providers. Under the PHE, the Centers for Medicare and Medicaid Services (CMS) reduced the number of provider time studies as a way to lower the administrative burden during the crisis. In hospitals that made amendments to their time study program because of the PHE, the clock is counting down with only two months to prepare and return to pre-pandemic time study practices.
This article takes a look at how we arrived at this point and offers five tips on how to ready your organization’s time study processes as the PHE expires.
Looking Back on COVID-19 PHE and Time Studies
On May 15, 2020, the PHE guidelines for provider time studies were published by CMS. As of March 2020, hospitals were no longer required to align with the 2313.2.E time study requirements in the CMS Provider Reimbursement Manual during the PHE declaration.
As part of the efforts to alleviate the administrative burden, hospitals could reduce the number of time studies required from the provider. The hospital could utilize one of three options.
Instead of one time study every month, a provider could complete a single time study every six months to total just two time studies for the year.
The hospital could utilize the time studies completed in the cost report prior to January 27, 2020, to replace time studies for the first six-month period of the COVID-19 PHE.
The hospital could use time studies from the previous year to replicate over to the corresponding time periods.
The hospital was still required to submit yearly provider allocation agreements as part of the filing report process. However, to ease this burden, CMS extended the due dates of the cost report by about two months for hospitals with a fiscal year ending March 1, 2020, through December 3, 2020.
Five Ways to Prepare for Time Study Process by the PHE Expiration
Depending on your facility, the end of the COVID-19 PHE results in your institution resuming the pre-pandemic operations of time studies. However, this may vary as some waivers and flexibilities were already terminated or made permanent.
Take a few moments to take the following actions if you implemented a time study operational change for the PHE:
Audit your current processes and assess what waivers and flexibilities may still be in effect for your organization.
Where indicated, prepare to reboot your processes to the levels required. Ensure your administrative staff knows their responsibilities and how to best achieve seamless communication with their providers. You should also revisit your provider activities to ensure the granularity is captured at the level your organization needs to understand your providers’ time spent at work.
Communicate to staff this return as soon as possible so they will have sufficient and advanced notice while setting clear expectations about what will be required.
Align with your MAC or your state plan to determine your transition plan so all parties are in agreement about what the processes will look like.
Take the opportunity to improve your time study process. Now would be a time to seek out process improvements that will lower the demands on your team. Can you shift to a system that uses mobile devices? What about an automated process that can reduce the effort to gather and prepare reports? This restart provides an opportunity to introduce better workflows and processes, so interrogate your process and look for gains, either large or small.
For entity-specific information, please refer to cms.gov/coronavirus-waivers.
These are a few tips to contemplate and act on in the lead-up to the PHE’s expiration, but it is by no means a complete list. It has been a trying few years and this transition can be smooth, especially with proper preparations in place.
If you want to explore how Time Study can help, and discuss how we can provide a modern, efficient way to manage time studies, please click the “Contact Us” button below.
