Reingruber Alert: Medicare/Medicaid Updates & CMS Expanded Accelerated/Advance Payment Program
3/30/2020 - By Claudia Reingruber, CPA
We are closely following the evolution of COVID-19 (Coronavirus) and have created a central location for sharing information to assist the healthcare industry. View our COVID-19 Resources for the Healthcare Community.
Medicare COVID-19 Updates
Extension of Medicare Cost Report Filing Deadlines
- CMS extended these cost report due dates:
- FYE 12/31/2019 - Now due 07/31/2020
- FYE 11/30/2019 - Now due 06/30/2020
- FYE 10/31/2019 - Now due 06/30/2020
- Extensions are automatic – no request needed
- Each MAC will post these extensions on their website
A Public Health Emergency (PHE) was Effective 03/01/2020
- Blanket Waivers under Section 1135 are Effective for SNFs
- Waiver of Section 1812(f) of SSA
- The requirement for a 3-day hospital stay is waived
- In certain cases, permits renewed SNF coverage when benefits exhausted without starting a new benefit period
- SNF does not have to justify use of these waivers
- UB04 must contain condition code "DR" to process
- Blanket Waivers also available for other provider types
- Click here for additional information on all Blanket Waivers
CMS Expanded Accelerated/Advance Payment Program
- Intended to increase cash flow due to COVID-19
- Expanded program is available during the Public Health Emergency
- Eligibility criteria - All must be satisfied:
- Must have submitted claims in the last 180 days
- Must not be in bankruptcy
- Must not be under active medical review
- Must not be under Program Integrity investigation
- Must not have any outstanding delinquent Medicare over payments
- Amount of Payment
- Provider/supplier must request a specific amount using MAC form
- Payment limited to amount billed in a 3-month period - with one exception
- For most hospitals - payment is limited to amount billed in a 6-month period
- How to Request Payment
- Request form may vary by MAC
- Obtain the proper request form from your MAC's website
- Timing of Payment
- Payment will be made within 7 calendar days of request
- Recoupment of Payment
- Will be automatic, through claims offset
- Will begin through claims offset after 120 days - with one exception
- For hospitals - will begin after one year
- Download CMS Fact Sheet for more information
Florida Medicaid COVID-19 Updates
Florida Medicaid Filing Deadlines
- AHCA eliminated sanctions for late Medicaid cost reports
- Late Medicaid cost reports will not be subject to sanctions during crisis
- Applies from 01/01/2020 until 60 days after the end of the state of emergency declaration
- 10/01/2020 rate setting will not change
- No extensions will be available for:
- Medicaid cost reports
- FRV surveys
- AHCA will use the most recent data they have to set rates
- To Ensure Optimal Rates at 10/01/2020
- Carefully evaluate your cost report filing options
- Consider early cost report submission if favorable
- Ensure FRV survey submitted to AHCA by COB 04/30/2020
Medicaid Section 1135 Waivers and Flexibilities
- Section 1135 Waivers approved by CMS based on state request
- Florida received the first waiver approval from CMS under Section 1135
- For a copy of the waiver request and CMS approval letter, click here.
- For the waiver requests and CMS approvals for other states, click here.
Visit our COVID-19 RESOURCE HUB for ongoing updates and information. Due to the ever-changing nature of this event, you should always consult the appropriate professionals.
QUESTIONS?
If you have questions about your particular circumstances, please contact our team or call (800) 477-7458.
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