May 2020

NEWS

Covid-19 News You Can Use
Questions answered on the Advance Payment Program and information on other government resources for COVID-19 relief for physicians


“Concerns with this program are the timelines and potentially exorbitant interest rates if the loan is not recouped within 210 days. ASCRS and the medical community are working to extend the timelines, as well as eliminate the interest as part of the next COVID-19 relief package.”

T
he passage of the Coronavirus Aid, Relief, and Economic Security (CARES) Act included the expanded authority for the Centers for Medicare & Medicaid Services (CMS) through the Accelerated and Advance Payment Program to provide funds to Medicare providers/suppliers during the pandemic. This is one of several financial relief programs that was part of the Act. The expanded Accelerated and Advance Payment Program is authorized during a period of a public health emergency when there is a disruption in claims submission or claims processing. These are loans and have to be paid back.
During an early April webinar about the Advance Payment Program, ASCRS Director of Government Relations Nancey McCann provided clarifying information on the funds available to physicians through this program. Since the time of the webinar, CMS announced on April 26 that it is reevaluating the amounts to be paid under this program and is suspending the program to Part B suppliers. CMS will not be accepting any new applications at this time.
Concerns with this program are the timelines and potentially exorbitant interest rates if the loan is not recouped within 210 days. ASCRS and the medical community are working to extend the timelines, as well as eliminate the interest as part of the next COVID-19 relief package.

Questions on the Advance Payment Program

During the webinar, Ms. McCann addressed qualifications for these payments. To qualify, a provider or supplier must have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form; they must not be in bankruptcy; they must not be under active medical review or program integrity investigation; and they must not have any outstanding delinquent Medicare overpayments.
With the quick rollout, Ms. McCann said many questions have emerged regarding procedures to apply, obtaining funds, timelines, specifics for recoupment, and more. ASCRS and other medical specialties raised several questions, which were answered in a meeting between CMS and the American Medical Association (AMA).

Process for requests

Ms. McCann first addressed the process for requests from the physician’s Medicare administrative contractor (MAC). Because the advance payments are rarely used, MACs have been using existing request forms, which can be confusing, Ms. McCann said. There is the possibility of creating a standardized form. There’s no need to answer the financial questions, such as anticipated receipts, expenditures, and cash position. The most important required information is that the request is based on the COVID-19 emergency and a signature of an authorized person should be included.

Requested loan amount

In terms of calculating the requested amount, she said that physician practices do not have to calculate amounts. All MACs have been instructed to use the physician’s claims for the period from October–December 2019 as the basis for the maximum advance payment amount, Ms. McCann said. Physicians may also choose to request less than 100% of the 3 months and could have the option of asking for 50% now and 50% at a later time.

Recoupment process

In terms of the recoupment process, recoupment of advance payments will begin 120 days after the funds have been disbursed and will be taken from claims submitted at that time until the full amount has been repaid. Physicians may request to repay the funds, or a portion of the funds, directly instead of them being recouped through claims submissions, and they may also request that payments be made on less than 100% of the claims during the repayment period.
With this program, you do have to pay back all of the money, Ms. McCann emphasized, unlike with the Paycheck Protection Program.

Interest

Ms. McCann said that no interest is charged on COVID-19 advance payments that are repaid within 210 days of the disbursement. If repayment within this timeframe is a hardship for the practice, physicians can request that the MAC provide an extended repayment plan. Interest is charged on extended repayment plan payments at 10.25% per the statute. CMS is checking with their general counsel regarding any flexibility they might have in this regard, but at this time it appears it would require a technical correction by Congress in the COVID-19 fourth stimulus package.

Disqualification

Ms. McCann also addressed concerns about disqualification from the Advance Payment Program. Investigations that would disqualify a physician from receiving these payments are program integrity and fraud investigations, she said. Targeted probe and educate (TPE) and RAC audits do not disqualify a physician, and those under investigation will have received notice from a program integrity contractor, she said.

Group practice application

Addressing whether a group practice can apply for an advance payment using its taxpayer identification number (TIN) or if each individual physician needs to apply, Ms. McCann said that CMS indicated to the AMA that advance payments must be requested at the individual national provider identifier (NPI) level, as this is how the MACs calculate the amount of payments to be advanced. If everyone in a group wants to request an advance payment, each physician would need to complete a form with their NPI. The payments will be made in the same way other Medicare payments are made; if the group’s claims are paid to a particular TIN, that is where the advance payment will be sent. However, it has been reported by ASOA members that individual MACs are only requiring the TIN for the group practice. “We encourage you to contact your MAC,” Ms. McCann said.

Administrative appeal rights

Finally, she addressed administrative appeal rights, noting that the MACs determine whether the physician qualifies for the advance payment and the amount they are eligible to receive. These determinations cannot be appealed. But physicians can still resubmit and/or appeal individual claims that are denied.

Other programs

During her presentation, Ms. McCann briefly touched on the small business loans (Paycheck Protection Program) that were also made available through the CARES Act. Initially, the Paycheck Protection Program authorized up to $349 billion in forgivable loans to small businesses to pay their employees during the pandemic. 
New legislation, the “Paycheck Protection Program and Health Care Enhancement Act,” has already been signed into law and replenishes the Paycheck Protection Program. This includes $310 billion in additional funding for the Paycheck Protection Program.

Provider Relief Fund

Ms. McCann mentioned that the CARES package also set aside a $100 billion public emergency fund for payments to providers. The Paycheck Protection Program and Health Care Enhancement Act includes $75 billion in additional funding for the Public Health and Social Services Emergency Fund (healthcare providers), $60 billion in separate disaster loans to small businesses, and $25 billion for COVID-19 testing.
The U.S. Department of Health and Human Services (HHS) announced in late April additional plans for distributing funds from the CARES Act Provider Relief Fund and stated that $50 billion would be for “general distribution” based proportionately on the provider’s 2018 net patient revenue. Of that $50 billion, $30 billion has already been distributed to providers, and $10 billion was released on April 24 for those who had already shared key data with HHS.
Those who received funds from the initial $30 billion and would like to receive additional funds must sign into the General Distribution Portal to provide revenue data. Providers must attest to each payment associated with their billing TIN. Providers will also need to attest to the terms and conditions for the first $30 billion. At this time, the General Distribution Portal is only for organizations that have already received payments through the CARES Act Provider Relief Fund. Initially, some states and specialties thought that physicians must also submit cost reports, but HHS has verified this is not the case. Physicians, however, do need to submit their revenue information so that it can be verified through the portal.
HHS has also released a user guide to assist with the data submission process. HHS will use the data to calculate providers’ proportional 2018 net revenue and provide funds via electronic deposit. Payments will go out weekly, on a rolling basis, as information is validated.

Editors’ note: All information in this article is current as of April 28, 2020.

Questions answered on the Advance Payment Program and information on other government resources for COVID-19 relief for physicians Questions answered on the Advance Payment Program and information on other government resources for COVID-19
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