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Practice relief options in recently signed CARES legislation

| March 30, 2020

Practice relief options in recently signed CARES legislation

On Friday, March 27, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security (CARES) Act. There are three provisions in this new law that will be of interest to allergists and your ability to remain open to see patients during the duration of the COVID-19 pandemic.

Each of these programs is available to allergists, however, there will be restrictions in place to prevent “double dipping.” You will need to consider each option and choose the one best for your practice.

It should be noted that all of these programs are only authorized for the duration of the national emergency and are not permanent.

  1. Grants for health care, Medicare- or Medicaid- enrolled providers to cover the revenue loss experienced due to the COVID-19 pandemic.
  2. Small Business Loans (which can be forgiven) to cover the cost of employee salaries, rent and other business expenses if the provider keeps his/her practice open during the pandemic.
  3. Advance payments from Medicare against future billing.

Health care provider “lost revenue/ increased cost” grants

The CARES Act establishes a $100 billion grant fund exclusively for health care providers who are enrolled in the Medicare and Medicaid program. The purpose of this fund is to provide grants to health care providers who have experienced a reduction in revenue or an unexpected increase in costs due to the COVID-19 pandemic. The money will be available during the period of the national emergency.

Allergists should expect a significant reduction in revenue because of a drop in patient volume and ancillary services like immunotherapy and allergen extract vials, lung function testing, and skin testing. Consequently, we can expect cash flow for allergy practices  to become a serious problem.

The Healthcare Provider Lost Revenue grant program is intended to provide medical practices with an infusion of money that will help replace the money lost due to reduced patient volume because of the COVID-19 pandemic.

The Department of Health and Human Services (HHS) is currently working on a formula to determine how to calculate a practice's lost revenue. This is lost revenue whether it is reduced volume for Medicare, Medicaid or commercially insured patients.

It may take a while for CMS to have all the necessary applications in place to get the money flowing, but these grants could be critically important for allergists experiencing a revenue decline due to COVID-19. More information on this will be shared as it becomes available.


Small Business Administration Loans/Grants

The CARES Act creates the Paycheck Protection Loan Assistance program which expands and modifies an existing Small Business Administration (SBA) Loan program. Before dismissing the idea of using a loan program, please read the details of this initiative before making a decision about this option.

The purpose is to help businesses that are struggling – including medical practices – due to the COVID-19 pandemic.

Under this program, small businesses (non-profit and for-profit entities) with fewer than 500 employees, can apply for an SBA loan to help pay for employee salaries as well as the business’s rent/mortgage or certain other business expenses incurred between February 15th and June 30th. Applicants will go through an approved bank for this program and will have to provide the bank with information showing your anticipated need (income and expenses). In calculating payroll, you will only include individual compensation up to $100,000.

The loan can be used to cover payroll, continuation of health benefits for your employees, rent, mortgage, utilities and interest on other loans you may have.

Loans will bear interest (no more than 4%). The bank is forbidden from asking for collateral or a personal guarantee. There is also no requirement that you seek credit elsewhere and get turned down before applying for these loans.

However…

All or a significant portion of this loan can be forgiven based on the percentage of people you employee during the pandemic compared to the same period in 2019. There are specific guidelines for this condition.

If you keep paying your employees, paying your rent, utilities, etc., and you maintain your workforce, all or most of the loan may be forgiven. If you decrease the number of people you employ, this will affect how much of your loan could be forgiven.

As part of the qualifying process, you will need to certify that:

  • You needed the money due to the drop in revenue caused by the COVID-19 pandemic.
  • The loan funds will be used for legitimate business purposes.
  • The loan will not duplicate assistance already received via another program.

Should you apply for one of the health care provider grants mentioned above, this would likely affect your ability to participate in this SBA program or limit the amount of money you can borrow under this program to avoid duplicate payments.

More details on this to follow. You can also visit the Small Business Administration website to get more information.


Medicare Advance Payments

The Coronavirus Aid, Relief, and Economic Security (CARES) Act authorizes CMS to expand the current Accelerated and Advance Payment Program to a broader group of Medicare providers and suppliers. The expansion of this program is only for the duration of the public health emergency.

An accelerated/advance payment is intended to provide necessary funds when there is a disruption in claims submission and/or claims processing.

CMS is authorized to provide accelerated or advance payments during the period of the public health emergency to any Medicare provider/supplier who submits a request to the appropriate Medicare Administrative Contractor (MAC) and meets the required qualifications.

To qualify for advance/accelerated payments the provider/supplier must:

  1. Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form.
  2. Not be in bankruptcy.
  3. Not be under active medical review or program integrity investigation.
  4. Not have any outstanding delinquent Medicare overpayments.

Allergists seeking an advance Medicare payment can request a specific amount using a form available on each Medicare Administrative Contractor’s website. Most providers will be able to request up to 100% of the Medicare payment amount for a three-month period. The provider can continue to submit claims as usual after the issuance of the accelerated or advance payment.

Repayment of the advance payments will commence 120 days after the date of issuance of the payment and physicians will have 210 days from the date of the accelerated or advance payment was made to repay the balance.

At the end of the 120-day period, the recoupment process will begin and every claim submitted by the provider will automatically be offset from the new claims to repay the advance payment. Thus, instead of receiving payment for newly submitted claims, your outstanding advance payment balance is reduced by the claim payment amount.

For more information and to get a copy of the form to request an advance payment, go to your Medicare Administrative Contractor’s website or call your MACs Corona Virus Hotline:

CGS Administrators – Jurisdiction 15
The toll-free Hotline Telephone Number: 1-855-769-9920
Hours of Operation: 7:00 am – 4:00 pm

First Coast Service Options Inc. – Jurisdiction N
The toll-free Hotline Telephone Number: 1-855-247-8428
Hours of Operation: 8:30 AM – 4:00 PM

National Government Services (NGS) – Jurisdiction 6 & Jurisdiction K
The toll-free Hotline Telephone Number: 1-888-802-3898
Hours of Operation: 8:00 am – 4:00 pm

Novitas Solutions, Inc. – Jurisdiction H & Jurisdiction L
The toll-free Hotline Telephone Number: 1-855-247-8428
Hours of Operation: 8:30 AM – 4:00 PM ET

Noridian Healthcare Solutions – Jurisdiction E & Jurisdiction F
The toll-free Hotline Telephone Number: 1-866-575-4067
Hours of Operation: 8:00 am – 6:00 pm CT

Palmetto GBA – Jurisdiction J & Jurisdiction M
The toll-free Hotline Telephone Number: 1-833-820-6138
Hours of Operation: 8:30 am – 5:00 pm ET

Wisconsin Physician Services (WPS) – Jurisdiction 5 & Jurisdiction 8
The toll-free Hotline Telephone Number: 1-844-209-2567
Hours of Operation: 7:00 am – 4:00 pm CT

 

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