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I am a huge fan of attorney Knicole Emanuel’s legal blog. Here’s a link to her most recent post about the current expiration date of the COVID-19 pandemic public health emergency (PHE). Unless it is renewed by the Centers for Medicare & Medicaid Services (CMS), the PHE will expire July 24, 2020.

Under the PHE, CMS has issued a lot of exceptions to various regulatory requirements and it’s possible that  these exceptions may be extended to Dec. 1, 2020. However, according to Ms. Emanuel, there is no indication that Recovery Audit Contractor (RAC) and Medicare Administrative Contractor (MAC) audits will be suspended until December 2020. In fact, she’s expecting those audits to begin again any day. Pre-payment review has apparently continued.

The RAC has a directive from CMS to audit hyperbaric oxygen therapy charges, and prior to COVID-19, many if not most providers of HBOT experienced some sort of audit from their MAC – whether they knew it or not. The situation is confusing and worrisome, particularly as some hospitals and physician practices are going under financially.


Dr. Fife sees patients at the CHI St. Luke's Hospital Wound Clinic in The Woodlands, Texas. For an appointment call (936) 266-2150.



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