So, as you know there is a call tonight from 5-6 pm with CMS. I am not sure they will answer questions about the additional Grant Money but in the event they do not here is what the actual release says:

“It is important to note, this funding is separate from the $100 billion provided in the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The CARES Act appropriation is a payment that does not need to be repaid. The Department of Health and Human Services (HHS) will be providing additional information on how health care providers and suppliers can access CARES Act funds in the coming weeks.” (Source: https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-09-mlnc#_Toc37220537)

So, what does that mean? Well, it means don’t sit around waiting for the information on how to get this money today, tomorrow or even next week. It was a great soundbite by the Administrator of CMS, but they are not ready to disperse or how they are going to do it. Please standby as I work on this.

Now, let me provide some analysis for the Medicare Advanced Payments since I am getting so many folks saying they are reading this person or that person and it its creating confusion. Y’all know me and that I am a good ole boy from South Georgia and I like things simple so here it is:

  1. The term “Part B Suppliers” includes the following: “The payments are available to Part A providers, including hospitals, and Part B suppliers, including doctors, non-physician practitioners, and durable medical equipment (DME) suppliers. While most of these providers and suppliers can receive three months of their Medicare reimbursements, certain providers can receive up to six months.
  2. “The advance and accelerated payments are a loan that providers must pay back. CMS will begin to apply claims payments to offset the accelerated/advance payments 120 days after disbursement. The majority of hospitals including inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and critical access hospitals will have up to one year from the date the accelerated payment was made to repay the balance. All other Part A providers and Part B suppliers will have up to 210 days to complete repayment of accelerated and advance payments, respectively.”

This means that they will begin the recoupment/offset at 120 days and certain hospitals as outlined above have up to 1 year to repay in full. All other Part A and Part B suppliers (I outlined who you are above) have up to 210 days to complete your repayment, so it is not all going to be recouped/offset at 120 days and if it is, you need to call your MAC and advise them that you have up to 210 days to repay the Advance Payment you received.

As always my source is: CMS Approves Approximately $34 Billion for Providers with the Accelerated/Advance Payment Program for Medicare Providers in One Week (https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2020-04-09-mlnc#_Toc37220537 )

Folks, again this is how the language reads from CMS and this is what I will be arguing on behalf of my clients that reach out to me in the event the MACs are not keeping with the spirit of how this is written and put out to the public for consumption. As always, feel free to comment and/or reach out with questions or concerns and I will do my best to walk through it with you.

Sean M. Weiss is a Partner and serves as VP/Chief Compliance Officer for DoctorsManagement, LLC based in Knoxville, TN. DoctorsManagement, LLC services more than 20,000 clients nation-wide and has been in existence since 1956. Weiss serves as an Investigator and expert witness in Federal and State cases as well as an expert or lead in Administrative Law Judge Hearings. During his 25-year career, Weiss has engaged in more than 200 cases working with law firms and health systems across the country. Weiss serves as a third-party compliance and regulatory officer for more than a dozen health care organizations across the country of varying sizes. For more information on Sean M. Weiss or DoctorsManagement, LLC visit us online at www.doctorsmanagement.com or contact us directly at 800.635.4040. You can also follow Sean on his biweekly Blog on LinkedIn (Sean M. Weiss “The Compliance Guy”) or at www.thecomplianceguyblog.com

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