NOTE: On April 26, 2020, the Centers for Medicare & Medicaid Services (CMS) announced that it is reevaluating the amounts that will be paid under its Accelerated Payment Program and suspending its Advance Payment Program to Part B suppliers effective immediately. The agency made this announcement following the successful payment of over $100 billion to healthcare providers and suppliers through these programs and in light of the $175 billion recently appropriated for healthcare provider relief payments. You can find the press release here.
In an effort to increase cash flow to healthcare providers and suppliers during the COVID-19 pandemic, the Centers for Medicare & Medicaid (CMS) recently expanded its Accelerated and Advance Payment Program to more Medicare Part A providers and Part B suppliers.
The streamlined process is intended to help providers and suppliers on the front lines of the COVID-19 epidemic with cash flow. The monies are separate from the $100 billion provided by the Coronavirus AID, Relief and Economic Security (CARES) Act and must be repaid.
To be eligible the provider/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.
- Not be in bankruptcy.
- Not be under active medical review or program integrity investigation.
- Not have any outstanding delinquent Medicare overpayments.
Those who qualify will be asked to request a specific amount and most will be able to request up to 100 percent of the Medicare payment amount for a three-month period. Inpatient acute care hospitals, children’s hospitals and some cancer hospitals can request up to 100 percent of the Medicare payment amount for a six-month period, while critical access hospitals can request up to 125 percent of their payment amount for a six-month period.
The streamlined process has reduced processing times for a request of an accelerated or advance payment to between four to six days, down from the previous timeframe of three to four weeks.
An informational fact sheet on the process and how to submit a request can be found here.
In addition, CMS recently announced that it was temporarily suspending some rules that focus on reducing supervision and certification requirements so that some healthcare practitioners can be hired and done so quickly. They include:
- Doctors can now directly care for patients at rural hospitals, across state lines if necessary, via phone, radio, or online communication, without having to be physically present. Remotely located physicians, coordinating with nurse practitioners at rural facilities, will provide staffs at such facilities additional flexibility to meet the needs of their patients.
- Nurse practitioners, in addition to physicians, may now perform some medical exams on Medicare patients at skilled nursing facilities so that patient needs, whether COVID-19 related or not, continue to be met in the face of increased care demands.
- Occupational therapists from home health agencies can now perform initial assessments on certain homebound patients, allowing home health services to start sooner and freeing home-health nurses to do more direct patient care.
- Hospice nurses will be relieved of hospice aide in-service training tasks so they can spend more time with patients.
Prior to the easing of the aforementioned rules, CMS also temporarily initiated the following:
- Permitted physicians whose privileges will expire to continue practicing at a hospital, and allowed new physicians to begin working prior to full hospital medical staff/governing body review and approval
- Lifted regulatory requirements regarding hospital personnel qualified to perform specific respiratory care procedures, allowing these professionals to operate to the fullest extent of their licensure
- Waived federal minimum personnel qualifications for clinical nurse specialists, nurse practitioners, and physician assistants so they can work at rural hospitals as long as they meet state licensure requirements, allowing for maximum staffing flexibility at such facilities
- Allowed physicians and non-physician practitioners to use telehealth technology to care for patients at long-term care facilities, rather than having to treat patients there in person
- Waived certain training and certification requirements for nurse’s aides at long term care facilities, to help address potential staffing shortages during the pandemic
- Waived paperwork requirements so that hospital doctors can use more verbal, rather than written medical orders
For a complete list of workforce flexibilities that CMS has permitted in recent weeks and years, go to: https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf
This is a rapidly changing situation. Before taking action, it’s always best to consult with legal counsel. The Health Law Offices of Anthony C. Vitale can assist you in navigating these changes. Feel free to contact us at 305-358-4500 or at firstname.lastname@example.org