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The Coronavirus Aid, Relief, and Economic Security Act (CARES Act or the Act) Impact on Post Acute Providers

Tiffany Karlin

March 30, 2020

Medicare Sequester

It eliminates the 2% Medicare sequester from May 1, 2020 through Dec. 31, 2020.  Starting May 1st, advisory to update all billing systems (i.e. Point Click Care, Matrix, WellSky) to remove any automatic adjustments or set-up to manually adjust.

Expanded Option for Accelerated Payments

In order to increase cash flow to providers of services and suppliers impacted by COVID-19 pandemic, the Centers for Medicare & Medicaid Services has expanded the current Accelerated and Advance Payment Program to a broader group of Medicare Part A providers and Part B suppliers. The expansion of this program is only for the duration of the public health emergency.  

Processing Time: Each Medicare Administrative Contractor (MAC) will work to review and issue payments within seven (7) calendar days of receiving the request.

Eligibility: To qualify for advance/accelerated payments 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 over-payments.

Amount of Payment: Qualified providers/suppliers will be asked to request a specific amount using an Accelerated or Advance Payment Request form provided on each MAC’s website (see website links below) Most providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three-month period.

Links to APR Forms:

Palmetto

Noridian

WPS

NGS

CGS

Novitas

Repayment: CMS has extended the repayment of these accelerated/advance payments to begin 120 days after the date of issuance of the payment.

More Details on CMS Fact Sheet. Click here.

Increase in Federal Medicaid Matching Funds

Each state’s Medicaid matching rate is increased by 6.2% for 2020. The increased federal share of Medicaid does not apply to the expansion population. Raising the federal share of Medicaid spending allows states to take their budgets further and help stave off cuts within Medicaid and to other programs.

Home-Based Services

The bill makes several policy changes regarding the provision of home-based health care services, which seek to increase access and decrease patient risk during the emergency period.

  • Face-to-Face Visits between Home Dialysis Patients and Physicians. This provision will reduce requirements during the COVID-19 emergency that pertain to face-to-face evaluations for home dialysis patients.
  • Enabling Additional Health Professionals to Order Home Health Services. This provision will expand the ability of physician assistants, nurse practitioners and certified nurse specialists with regards to the certification of home health services and document-related requirements.
  • Facilitating Home and Community-based Support Services during Hospital Stays. This provision will expand certain state and community-based services guidelines to include self-directed personal assistance services and attendant services and supports. Many of these policy changes also will apply to Medicaid home health services.
  • Telehealth. The legislation will make several policy changes regarding the provision of telehealth services, which may increase access during the emergency period. These include:
    • Medicare Telehealth Flexibilities. Telehealth Services During Certain Emergency Periods Act of 2020 – a sub-part of H.R. 6074 – will be to give the Health and Human Services Secretary authority to waive the geographic and originating site requirements, among other policies, and promote the use of telecommunications systems in home health during the emergency period, including remote patient monitoring that is consistent with the plan of care.
    • Enhancing Medicare Telehealth Services for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs). During the emergency period, FQHCs and RHCs will be able to serve as distant sites to provide telehealth services to patients in their homes and other eligible locations. The legislation will reimburse FQHCs and RHCs at a rate that is similar to payment for comparable telehealth services under the physician fee schedule.
    • Using Telehealth for Hospice Recertification. This section allows hospice recertifications to be completed via telehealth, rather than a face-to-face visit, during the emergency period.
    • Telehealth Grants. Telehealth Network and Telehealth Resource Centers Grant Programs awards 5-year grants through the Department of Health and Human Services (HHS) Telehealth Resource Center to allow long-term care, home care and other preventive health care providers to utilize telehealth technologies, through telehealth networks. The program will receive an appropriation of $29 million for FY 2021 through 2025. The grants will allow nursing facilities to enable residents to participate in “virtual visits” with loved ones while the health risk of in-person visits remain high during the pandemic.
    • High Deductible Health Plan (HDHP) Exemption for Telehealth Services. This section allows HDHPs with HSAs to cover telehealth services before a patient reaches his or her deductible amount.
    • CMS Telehealth Tool Kit. Click here.

Centers for Medicare & Medicaid Services

The bill will provide $200 million for CMS to assist nursing homes with infection control and support states’ efforts to prevent the spread of coronavirus in nursing homes.

Elimination of Medicare Part B Cost-Sharing for the COVID-19 Vaccine:

The Act enables Medicare Part B beneficiaries to receive a COVID-19 vaccine in Medicare Part B with no cost-sharing.

3-Month Fills and Refills of Covered Medicare Part Drugs:

Medicare Part D plans will be required to provide up to a 90-day supply of a prescription medication if requested by a beneficiary during the COVID-19 emergency period.

Increase in Medicare Funding and Delays in Medicare Reductions:

Scheduled reductions to Medicare Payments for durable medical equipment will be postponed through the length of the COVID-19 emergency period.

Charitable Deductions

Permits Americans to deduct $300 of charitable contributions to charitable organizations regardless of whether they itemize their taxes during 2020; while small, this is an important step toward recognizing the value of non-profits.  Increases the limit on charitable contributions for individuals and corporations who do itemize their taxes during 2020 by eliminating the 50% limitation for individual donors.

Reauthorization of Health Professions Workforce Programs:

Reauthorizes appropriations to provide grands to designated health professions schools and other public and nonprofit health or educational entities.

Further reauthorizes appropriations for awards related to infrastructure development and maintenance and enhancements of entities providing health care workforce education programs and area health education center programs, for grants related to public health training centers and trainee-ships, for pediatric specialty loan repayment programs, and for programs evaluating health professions workforce issues and policies, including the National Center for Health Care Workforce Analysis.

Health Workforce Coordination:

Directs Secretary of Health and Human Services to develop a comprehensive and coordinated plan with respect to the healthcare workforce development programs of the Department of Health and Human Services, including education and training programs.

Education and Training Relating to Geriatrics:

Reauthorizes and updates the section of the Public Health Service Act related to education and training relating to geriatrics. It provides for grants, contracts, or agreements to health education programs for the establishment or operation of Geriatrics Workforce Enhancement Programs.

Nursing Workforce Development:

The Act reauthorizes and revises Title VIII of the Public Health Service Act, which covers programs supporting nurse workforce training.

As cited from: Ballard Spahr, American Hospital Association, American Healthcare Association and LeadingAge.

To review other provisions from the CARES Act, click here.

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