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.