Month: April 2020

As part of the CARES Act, Congress established a Provider Relief Fund, with $50 billion allocated to Medicare facilities and providers impacted by COVID-19 and based on eligible providers’ 2018 net patient revenue. Many AOPA member received funding when the initial $30 billion was distributed between April 10 and 17. Late last week, the Department of Health and Human Services (HHS) released information on the remaining $20 billion, presenting an opportunity for additional funding.

The remaining $20 billion will be distributed in two ways – an automatic distribution to Medicare providers who previously submitted cost reports, and subsequent waves of distributions based on Medicare providers’ applications in a General Distribution Portal. HHS’ goal is to augment providers’ allocations so that all funding is proportionate to each provider’s share of 2018 net patient revenue. For example, certain providers (such as children’s hospitals) have a small Medicare proportion and were allocated a small amount from the initial $30 billion Distribution, and therefore are eligible to receive more from the $20 billion Distribution. HHS has stated that the General Distribution will ideally replace a percentage of providers’ annual gross receipts, sales, or program services revenue during this period.

Medicare providers who have already received a payment from the Provider Relief Fund are eligible to apply for additional funds by submitting data about their annual revenues and estimated COVID-related losses via a General Distribution Portal. While providers received the initial funds automatically, in this second disbursement, HHS will require providers to submit their revenue information through the General Distribution Portal, so the cost report data can be verified. HHS has noted that any provider who received a payment from the Provider Relief Fund as of 5pm ET Friday, April 24 can and should apply for additional funding via the Provider Relief Fund Application Portal.

More information on the application process (including all information needed for the application) can be found in an FAQ and user guide created by HHS.

HHS will be processing applications submitted through the General Distribution Portal in batches every Wednesday at noon ET. The funds will not be distributed on a first-come-first-served basis; therefore, applicants will be given equal consideration regardless of when they apply before each processing deadline and will not be penalized for taking several days to collect the required information. HHS plans to issue payments on a weekly, rolling basis, as information is validated, estimating the first payments will go out 10 business days after the first submission deadline. That said, the intent is to disburse the funds quickly.

As reported yesterday by AOPA, as of April 26 the Centers for Medicare & Medicaid Services (CMS) ended its Medicare Accelerated and Advanced Payment Program because of the additional Provider Relief funding.  Those who were expecting advanced payments should consider applying for this additional funding.

If you are looking for a deeper dive into O&P policy issues including COVID-related legislation join us Wednesday, May 6 from 1 to 3pm ET for  the 2020 Virtual Policy Forum.

For any questions on the HHS disbursements or the Policy Forum, please contact Justin Beland, AOPA’s Director of Government Affairs at jbeland@AOPAnet.org.

Yesterday, April 26, 2020, the Centers for Medicare and Medicaid Services (CMS) announced that it is re-evaluating payments made to Medicare Part A providers through the recently expanded Accelerated Payment Program and suspending the Advance Payment Program for Medicare Part B providers effective immediately.

The Medicare Accelerated and Advance Payment Program (AAP) is a longstanding program that authorizes Medicare contractors to make up to three months of expected Medicare payments to Part A providers (accelerated payments) and Part B providers (advance payments) during a public health emergency that results in the disruption of claim submission or claim processing. In early April, CMS announced it was expanding the AAP program to include Medicare Part A and Part B providers impacted by the COVID-19 Public Health Emergency, allowing them to receive accelerated and advance payments from Medicare as a means to temporarily maintain adequate cashflow to support their businesses.

The April 26 announcement indicates that due to Medicare accelerated and advance payments of approximately $100 billion to providers through the AAP program to date, and the $175 billion of appropriated grant funds through COVID-19 related provider relief legislation, CMS is reevaluating the AAP program and is reviewing all new and pending applications for Medicare Part A accelerated payments and suspending the Medicare Part B advance program outright, no longer accepting new applications for advance payments from Part B providers.

The CMS announcement may be reviewed here. AOPA is reviewing the CMS announcement including its potential impact on AOPA members and will provide CMS with appropriate comments.

Questions regarding this may be directed to Joe McTernan at jmcternan@AOPAnet.org or Devon Bernard at dbernard@AOPAnet.org.

As part of its ongoing efforts to provide relief during the COVID-19 Public Health Emergency (PHE), the Centers for Medicare and Medicaid Services (CMS) has expanded the Medicare Accelerated and Advanced Payment Program to temporarily increase cash flow for impacted providers.  The program, which has been in existence for many years, is “intended to provide necessary funds when there is a disruption in claims submission and/or claims processing. Expedited payments can also be offered in circumstances such as national emergencies, or natural disasters in order to accelerate cash flow to the impacted health care providers and suppliers.” As part of CMS’ response to the COVID-19 PHE, the Accelerated and Advance Payment Program has been expanded to include a larger number of Part A and Part B Medicare providers and time frames for issuing accelerated and advance payments have been significantly reduced from several weeks to approximately seven days.

The Accelerated and Advance Payment Program allows eligible providers to request up to three months of expected Medicare payments to be made if their business operations have been impacted by the COVID-19 PHE.  In order to be eligible to participate in the program, providers must have billed Medicare within the last 180 days, cannot be in bankruptcy, cannot be under active medical review, and cannot have any delinquent Medicare overpayments.  Repayment of Medicare accelerated, or advance payments will begin after 120 days of the request and all re-payment must be completed within 210 days of the request.

CMS has published a very informative fact sheet on the Medicare Accelerated and Advance Payment Program, including additional resources on how to apply for accelerated and advance payments.

The decision regarding whether to apply for Medicare accelerated and advance payments should be based on the individual needs of your practice but may be a viable option to temporarily increase cashflow during the COVID-19 PHE.

Questions regarding this issue may be directed to Joe McTernan at jmcternan@aopanet.org or Devon Bernard dbernard@aopanet.org.

This is an update to the April 2, 2020 announcement, where AOPA informed you that the Centers for Medicare and Medicaid Services (CMS) have suspended most Medicare fee-for-service medical review activity for the duration of the COVID-19 Public Health Emergency (PHE).

AOPA has confirmed that CMS, effective immediately, will also not be sending out any additional documentation requests (ADRs), either by mail or over the phone, as part of the Comprehensive Error Rate Testing (CERT) program. This suspension of documentation requests and reviews will be in place until further notice from CMS.

AOPA has also confirmed that any claims under the Targeted Probe and Educate (TPE) program which were denied due to no response on or after March 1, 2020 will be reversed.

Questions? Contact Joe McTernan at jmcternan@AOPAnet.org, or Devon Bernard at dbernard@AOPAnet.org.

In response to the declaration of a public health emergency (PHE) due to COVID-19, the Centers for Medicare and Medicaid Services (CMS) has suspended most Medicare fee-for-service medical review activity (audits) for the duration of the PHE.

The suspension of audits includes pre-payment reviews by the DME MACs under the Targeted Probe and Educate (TPE) program, and post payment reviews by the DME MACs, Supplemental Medical Review Contractor (SMRC), and the Recovery Audit Contractor (RAC).

In the March 26 SmartBrief, AOPA reported that  Performant Recovery, the RAC contractor, had suspended the issuance of any new Additional Documentation Requests (ADRs) associated with complex medical review audits but would continue to perform automated reviews including audits based on reasonable useful lifetime (RUL).  AOPA has since verified that the RAC will also be suspending automated reviews.

CMS has indicated that audits may still be conducted in cases where fraud and abuse is suspected.

Review CMS’s Novel Coronavirus (COVID-19) Provider Burden Relief Frequently Asked Questions here.

Questions? Contact Joe McTernan at jmcternan@AOPAnet.org, or Devon Bernard at dbernard@AOPAnet.org.

For other COVID-19 updates visit the COVID-19 Responses and Resources webpage. To see how other AOPA members are responding and to share your responses visit the Member to Member resources on the AOPA Co-OP.