KY Cabinet for Health & Family Services Office of Inspector General Division of Health Care Long Term Care Provider Newsletter
The Long Term Care Provider Newsletter published by the Cabinet for Health & Family Services Office of Inspector General Division of Health Care is a great resource for KY facilities.
Joint Cybersecurity Advisory
CISA, FBI, and HHS have credible information of an increased and imminent cybercrime threat to U.S. hospitals and healthcare providers. CISA, FBI, and HHS are sharing this information to provide warning to healthcare providers to ensure that they take timely and reasonable precautions to protect their networks from these threats.
HHS Updates Provider Relief Fund FAQs
MLN Matters SE20011 was revised on 11/9/2020 to clarify the Skilled Nursing Facility (SNF) Benefit Period Waiver.
Statements worthy of reviewing regarding the Benefit Period Waiver:
1. Providers may utilize the additional 100 SNF days at any time within the SAME SPELL OF ILLNESS.
2. Ongoing skilled care in the SNF that is unrelated to the PHE does NOT qualify for the Benefit Period Waiver.
Blog by Kyle Fritsch, Billing Manager
Medicaid Oxygen Fee Screens Based on DME Fee Schedule Amounts
The Medicaid oxygen fee screens are based on the DME fee schedule amounts. The email below is from Cabinet for Health and Family Services and addresses the effective date for the oxygen fee screen amounts.
Each year Kentucky Medicaid is required to provide an Upper Payment Limit demonstration for CMS on DME codes covered by Kentucky Medicaid. This demonstration must reflect reimbursement rates for Kentucky Medicaid are set at or below the rates for the same codes listed by Medicare. Kentucky Medicaid was notified by CMS that we were out of compliance and must make adjustments to our fee schedule. To bring Kentucky Medicaid into compliance the Department for Medicaid Services immediately ordered a rate change adjustment to the 2020 DME fee schedule retroactive to 1/1/2020. This resulted in paid claims with any codes having rate decreases to automatically trigger a recoupment. The recoupment was in error. The recouped amounts will be reprocessed and repaid. Kentucky Medicaid apologizes for the late notice and any inconvenience that this has or may cause. The new effective date of the rates is 11/15/20.
Humana Medicare Advantage Change to Reimbursement Methodology January 1, 2021
Humana recently mailed a letter to providers notifying them of their new payment methodology change effective January 1, 2021. Humana is changing the reimbursement methodology to Levels. Please see the attached memo and if you wish to object, notify Humana at the address listed in the memo.
Medicaid recently updated the oxygen reimbursement amounts the week of September 14th. The website states the oxygen reimbursement changes are effective 1/1/20. The reimbursement amounts are below and reflect the amounts listed on the website (link below). Watch Sarah's video for more details.
Civil Money Penalty (CMP) Reinvestment Application – In-Person Visitation Aids
The Centers for Medicare and Medicaid Services (CMS) recognizes that considerations allowing for visitation in each phase of re-opening may be difficult for residents and their families, CMS has developed this application template for request for the use of CMP funds to provide nursing homes with in-person visitation aids.
Funding for tents and Plexiglas (or similar product), are limited to a maximum of $3,000 per facility. Note, when installing tents, facilities must ensure appropriate Life Safety Code (LSC) requirements found at 42 CFR 483.90 are met, unless waived under the Public Health Emergency (PHE). All applicants must agree to the requirements defined in the project application.
Trump Administration Announces $20 Billion in New Phase 3 Provider Relief Funding
Under this Phase 3 General Distribution allocation, providers that have already received Provider Relief Fund payments will be invited to apply for additional funding that considers financial losses and changes in operating expenses caused by the coronavirus. Previously ineligible providers, such as those who began practicing in 2020 will also be invited to apply, and an expanded group of behavioral health providers confronting the emergence of increased mental health and substance use issues exacerbated by the pandemic will also be eligible for relief payments.
How is the $2 billion incentive payment to skilled nursing facilities and nursing homes being determined?
In order for a facility to be eligible for payment, they must pass two initial gateway qualification tests on both their rate of infection and rate of mortality. First, a facility must demonstrate a rate of COVID infections that is below the rate of infection in the county in which they are located. This benchmark requirement for infection rate reflects the goal of the incentive program to recognize and reward facilities that establish a safer environment than the community in which they are located. Second, facilities must also have a COVID death rate that falls below a nationally established performance threshold for mortality among nursing home residents infected with COVID.
Public Health Emergency (PHE) Extension
Secretary Azar used his authority in the Public Health Service Act to declare a public health emergency (PHE) in the entire United States on January 31, 2020 giving us the flexibility to support our beneficiaries, effective January 27, 2020. The PHE was renewed on April 21, 2020, July 23, 2020, and October 2, 2020, effective October 23, 2020.
HHS Reporting Requirements Change as of September 19, 2020
This notice informs recipients of the categories of data elements that recipients must submit for calendar years 2019 and 2020 as part of the reporting process.
KY Medicaid Lab Fee Screen Amounts Updated
For SNF’s that have Medicaid only patients, Medicaid has recently updated the Lab fee screen amounts. SNF’s will need to update their software accordingly for the changed fee screen amounts.
Questions about the COVID-19 $270 add-on
There has been much discussion about billing Medicaid for COVID-19 patients and receiving the $270 add-on. The original FAQ document stated the Skilled Nursing Facility (SNF) had to receive a negative test result before the add-on billing ceased. There have been multiple discussions between SNFs due to the Office of Inspector General (OIG) stating residents were not required to be given the COVID-19 test to show a negative result.
Blog by Sarah McIntosh, Director of Operations
LeadingAge Kentucky 2020 Annual Conference
Join LeadingAge Kentucky for the 2020 Annual Conference on October 15-16, 2020. We'll have 2 team members as featured presenters during this virtual conference. More info on the conference coming soon!
Program Title: Make the Most of Your Provider Relief Funds: Tips to Successfully Account for Expenses
Date: October 15, 1:00-2:00 EST
Presenter: Sarah McIntosh, Director of Operations
Program Title: 7 Tips to Improve Your Accounts Receivable
Date: October 16, 10:30-11:30 EST
Presenter: Leah Shoulders, Billing Manager
IRS temporarily stops mailing notices to taxpayers with balances due
The IRS has suspended the mailing of three notices – the CP501, the CP503 and the CP504 – that go to taxpayers who have a balance due on their taxes. Although the IRS continues to make significant reductions in the backlog of unopened mail that developed while most IRS operations were closed due to COVID-19, this temporary adjustment to processing is intended to lessen any possible confusion that might be associated with delays in processing correspondence received from taxpayers.
Trump Administration Announces $2 Billion Provider Relief Fund Nursing Home Incentive Payment Plans
Under the leadership of President Trump, the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is announcing the details of a $2 billion Provider Relief Fund (PRF) performance-based incentive payment distribution to nursing homes. This distribution is the latest update in the previously announced $5 billion in planned support to nursing homes grappling with the impact of COVID-19. Last week, HHS announced it had delivered an additional $2.5 billion in payments to nursing homes to help with upfront COVID-19-related expenses for testing, staffing, and personal protective equipment (PPE) needs. Other resources are also being dedicated to support training, mentorship and safety improvements in nursing homes.
Infection Control Distribution is to be spent for costs associated with COVID-19
HHS distributed an initial $2.5 billion of the Nursing Home Infection Control Distribution funding on Thursday, August 27, 2020. Eligible nursing homes and skilled nursing facilities received a per-facility payment of $10,000 plus a per-bed payment of $1,450 in the first round of this distribution.
The Infection Control Distribution is to be spent for costs associated with administering COVID-19 testing for both staff and residents; reporting COVID-19 test results to local, state, or federal governments; hiring staff to provide patient care or administrative support; incurring expenses to improve infection control, including activities such as implementing infection control “mentorship” programs with subject matter experts, or changes made to physical facilities; and providing additional services to residents, such as technology that permits residents to connect with their families if the families are not able to visit in person.
Just like the other Provider Payment Relief payments, providers will have 90 days from receipt of payment to attest to the terms and conditions. The terms and conditions were wrongly placed under the link for the 2.5 billion SNF distribution.
Blog by Sarah McIntosh, Director of Operations
Get all the Kentucky COVID testing details, instructions, links and answers to your FAQs in this blog.
Kentucky COVID-19 testing, reimbursement, and support details:
To aid in advancing ongoing COVID-19 surveillance testing, the Kentucky Department for Public Health issued an order on July 9, 2020 indicating that a licensed clinician’s order is not required for a clinical laboratory to perform or bill for a COVID-19 FDA-approved diagnostic test. This guidance is intended to demonstrate Governor Andy Beshear’s continuing commitment to protect our most vulnerable citizens residing in Kentucky’s Long Term Care Facilities from COVID-19. Accordingly, effective immediately, the CHFS will continue its financial support of ongoing COVID-19 surveillance testing for residents and staff of LTC providers. The guidelines are based on what is currently known about the transmission and severity of COVID-19..
Team Kentucky Reimbursement Instructions:
This contract is established to provide for reimbursement to providers, clinics and/or laboratories for testing costs of COVID-19 on non-insured and non-Medicaid eligible citizens of the Commonwealth, staff and residents of Long-Term Care Facilities, or any other population identified by the Secretary of the Cabinet for Health and Family Services.
CHFS Surveillance COVID-19 Testing for Long-Term Care Facilities Frequently Asked Questions (FAQs):
Apply Now: CARES ACT Provider Relief Fund Application Portal Now Open for Certain Medicare Providers
The U.S. Department of Health and Human Services (HHS) is distributing payments in the Phase 2 General Distribution of the Provider Relief Fund as part of ongoing efforts to offer financial relief to providers impacted by coronavirus disease 2019.
Allocations of CARES Act Provider Relief Fund for Nursing Homes
The Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is announcing the details of the next CARES Act-authorized nursing home Provider Relief Fund (PRF) distribution.
Flu Vaccine Amounts have been published for 2020-2021 Season
The Medicare Part B payment allowance limits for seasonal influenza and pneumococcal vaccines are 95% of the Average Wholesale Price (AWP) as reflected in the published compendia except where the vaccine is furnished in a hospital outpatient department. When the vaccine is furnished in the hospital outpatient department, payment for the vaccine is based on reasonable cost. Annual Part B deductible and coinsurance amounts do not apply for the influenza virus and the pneumococcal vaccinations. All physicians, non-physician practitioners, and suppliers who administer these vaccinations must take assignment on the claim for the vaccine.
PRIOR AUTHORIZATION TO RESUME AUG. 1st
Effective with dates of service beginning 8/1/2020, prior authorizations will resume with the exception of Behavioral Health and Substance Use Disorder (SUD) services. Behavioral Health and SUD services are defined as services provided by any Behavioral Health Provider type (02, 03, 04, 05, 06, 23, 26, 30, 62, 63, 66, 67, 81, 82, 83, 84, 89, 92), services listed on the Behavioral Health and Substance Abuse Services Inpatient and Outpatient fee schedules, and services listed on the Community Mental Health Center (CMHC) Mental Health Substance Abuse Codes and Units of Service fee schedule.
Medicare payment rates and SNF VBP Program..
CMS issued final rule for Fiscal Year (FY) 2021 that updates Medicare payment rates and the value-based purchasing program for SNFs.
August Performance Score Reports now available to download
The August Performance Score Reports (PSRs) for the fiscal year (FY) 2021 Skilled Nursing Facility Value-Based Purchasing (SNF VBP) Program are now available to download. The PSRs provide SNFs with their performance information for the third year of the SNF VBP Program, including the incentive payment multiplier that will be applied to SNF Medicare fee-for-service claims from October 1, 2020 through September 30, 2021. The PSRs are distributed to SNFs via the Quality Improvement and Evaluation System (QIES) Certification and Survey Provider Enhanced Reports (CASPER) reporting system.
To receive your Medicare Rates for FY 2021, contact one of our client Managers today!
Flu and Pneumonia Billing in a Skilled Nursing Facility (SNF)
For SNF’s, Medicare B pays for patients that receive the influenza, pneumococcal and Hepatitis B vaccines. As a reminder, the vaccines are a separate Part B inpatient benefit when rendered to beneficiaries in a covered Part A stay. Therefore, the SNF can be reimbursed for the vaccines given to all patients that have Medicare B, regardless if the patient is using Medicare A benefits or not.
Reference the Medicare Claims Processing Manual, Chapter 6, Section 20.4 for details.
Blog by Sarah McIntosh, Director of Operations
**BLOG UPDATED 8/18/2020: HHS delayed the additional details regarding the reporting instructions. HHS stated providers will receive detailed instructions and data template well before the reporting system’s October 1 availability.
Department of Health and Human Services (HHS) to release reporting instructions by August 17, 2020.
Provider Relief Fund (PRF) recipients that received one or more payments exceeding $10,000 will be required to submit future reports of how the PRF were spent.
• All recipients must report on their expenditures through December 31, 2020 by February 14, 2021.
• If there are remaining funds to be spent on December 31, 2020, a second and final report will be due July 31, 2021.
• Recipients who have expended all their funds prior to December 31, 2020 may submit a single report any time after October 1, 2020 but before February 15, 2021.
** BLOG UPDATED 8/6/20: This deadline has now been extended to August 28, 2020.
Dear Kentucky Medicaid & CHIP Leadership
I wanted to send you a note to follow up on the email that CMS sent out last Friday announcing HHS’ extension of the deadline for qualifying Medicaid & CHIP providers to apply for the Medicaid & CHIP Provider Relief Fund distribution.
CMS has been in continuous discussions with our partners at the Health Resources and Services Administration (HRSA) about the status of applications for this distribution. This email is intended to provide you with an update on the number of providers from your state that have applied.
As of July 15th, 143 qualifying Medicaid & CHIP eligible providers in Kentucky have applied for the Medicaid & CHIP Provider Relief Fund distribution out of the 22,751 providers identified in the data that your team supplied to CMS. Of these, 91 Medicaid & CHIP providers have been paid from this distribution. To ensure that all qualifying providers are aware of the opportunity, as well as the new application deadline, we are requesting that states reach out to your medical, dental, and long-term services and supports (LTSS) providers to remind them that they can begin the application process here.
To support these efforts, we’ve included below some resources that the HRSA team has released on the Provider Relief Fund that you can share:
The bipartisan Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Paycheck Protection Program and Health Care Enhancement Act provide $175 billion in relief funds to hospitals and other health care providers, including those on the front lines of the coronavirus response. A portion of these funds, under the Medicaid and Children’s Health Insurance Program (CHIP) Provider Distribution, provide help for providers and clinicians who treat our most vulnerable populations, including low-income and minority patients. This is allocated for eligible providers that participate in state Medicaid and CHIP Programs and that did not receive a payment from the Provider Relief Fund General Allocation. The payment to each provider will be approximately 2 percent of reported gross revenue from patient care.
The Health Resources & Services Administration (HRSA) released a Fact Sheet for Medicaid and CHIP Providers that is now available on the Provider Relief Fund website.
A recording of the June 25 webcast is now available at https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html.
Frequently Asked Questions (FAQs)
In order to better address your most important concerns, HRSA has updated their FAQs to address common questions, including those submitted during the previous webcasts. The FAQs include expanded information on eligibility, application, payment process, and more.
Medicaid and CHIP Provider Distribution Instructions and the Medicaid and CHIP Provider Distribution Application Form are available at hhs.gov/providerrelief. HRSA recommends downloading and reviewing these documents to help you complete the process through the Enhanced Provider Relief Fund Payment Portal.
For additional information, please call the Provider Support Line at (866) 569-3522; for TTY, dial 711. Hours of operation are 7 a.m. to 10 p.m. Central Time, Monday through Friday. Service staff members are available to provide real-time technical assistance, as well as service and payment support.
Summary of Provider Relief Fund Payments.
General Distribution Payment:
Two separate payments on April 10-17 and April 24
Attestation deadline for April 10-17 payment was July 9
Attestation deadline for April 24 payment is July 23
Targeted SNF-Only Distribution:
Payment sent on May 22
Attestation deadline for May 22 payment is August 20
Targeted Medicaid/CHIP Distribution:
Eligible for Medicaid providers who have not received General Distribution payment
Applications must be submitted by July 20
Do I have to submit a quarterly report to HHS for April, May and June 2020 quarter?
No. All Recipients of the Provider Relief Fund payments who attest and agree to the Terms and Conditions, do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will submit a report containing all information necessary to comply with the reporting requirements of the CARES Act. However, HHS will be requiring recipients to submit future reports of how the Provider Relief Funds were spent. HHS will notify recipients of the content and due date.
What type of Documentation do I need to provide for the Provider Relief Fund Payments?
All expenses and lost revenues should be linked to COVID-19. Providers should not only track the expense but record what the item was used for and how it related to COVID-19. HHS has clarified that the Provider Relief Fund payments can be used for expenses incurred after January 1, 2020. These expenses must be related to COVID-19. HHS has said it will reconcile payments to expenses and lost revenues at the end of the pandemic.
What if I have excess Provider Relief Fund Payments that I do not spend?
HHS will provide directions on how to return the unused funds.
KENTUCKY LEVEL OF CARE SYSTEM (KLOCS)
Starting August 3, 2020, all nursing and ICF/IID facilities will be required to use Kentucky Level of Care System (KLOCS) to submit Level of Care (LOC) applications and receive payment. Every facility will need a Kentucky Online Gateway (KOG) account to access KLOCS. Below is the TAKE ACTION NOW email that Department for Medicaid Services (DMS) has sent out.
Your facility must provide the Department for Medicaid Services (DMS) the names of individuals (2 max) responsible for managing your organization and its users in Kentucky Online Gateway (KOG). DMS will assign those individuals the KOG role of Organization Administrator. The Organization Administrator is responsible for granting and removing access to KLOCS on behalf of your organization.
How do I provide DMS this information?
Email KLOCSOrgAdmin@ky.gov the following information by 7/17/2020:
- Name First and Last Name (2 people max per facility)
- Their email addresses
Guides for KOG Account Creation, the Organization Administrator Role, and Multi Factor Authentication (MFA) Set-Up will be available on the DMS KLOCS training page prior to the August 3, 2020 go-live.
What happens if my facility does not identify an Organization Administrator?
Without an Organization Administrator, your staff will NOT be able to access KLOCS to submit new LOC applications, initiate a request for PASRR Level II evaluations, nor manage active LOCs. This will impact your facility’s ability to receive payment.
If you have already provided DMS this information, please follow-up to confirm they received the initial request.
Frequently Asked Questions about Taxation of Provider Relief Payments
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), enacted on March 27, 2020, appropriated $100 billion for the Public Health and Social Services Emergency Fund (Provider Relief Fund). The Paycheck Protection Program and Health Care Enhancement Act, enacted on April 24, 2020, appropriated an additional $75 billion to the Provider Relief Fund. This funding will be used to reimburse eligible health care providers for health care-related expenses or lost revenues that are attributable to the COVID-19 pandemic.
Kentucky Department for Medicaid Services Update on MDS Requirements
Effective October 1, 2020, Kentucky Medicaid will be requiring the reporting of the PDPM payment codes on the OBRA assessments when not combined with a 5‐day SNF PPS assessment.
CMS plans to end the emergency blanket waiver
CMS announced plans to end the emergency blanket waiver requiring all nursing homes to resume submitting staffing data through the Payroll-Based Journal (PBJ) system by August 14, 2020. The memorandum also provides updates related to staffing and quality measures used on the Nursing Home Compare website and the Five Star Rating System.
KLOCS Go-Live and Training
Kentucky Level-of-Care Systems (KLOCS) Go-Live and Training: AUGUST 3, 2020 Go to the following link for postings regarding web-based trainings.
Important Update: MEDICAID RATES - July 1
*Estimated Medicaid 1.5% Inflation Adjustment effective July 1, 2020
*DMS will not apply rate sanctions to the per diem rates effective July 1, 2020 and October 1, 2020, unless the Public Health Emergency ends prior to these dates.
CMS Issued an Emergency Grant Program
CMS issued an emergency grant program, Communicative Technology Project, to assist in alleviating communication limitations due to COVID-19. Certified nursing facilities can apply for a Civil Money Penalty (CMP) fund grant for up to $3,000 to cover the costs of certain communicative technology devises and accessories.
Reminder that the CMP Grant opportunity is set to expire in July 2020.
Blog by Rhonda Houchens, Director of Operations
Kentucky Department for Medicaid Services Update on MDS Requirements
Medicare Fee-for-Service (FFS) Response to the Public Health Emergency on the Coronavirus (COVID-19)
CMS provided clarification on provider utilization of the three day waiver and the benefit period waiver. Additional billing instructions have been provided for troublesome benefit period waiver claims.
Provider Guidance: Phased Reduction of Restrictions for Long Term Care Facilities
This guidance is provided in accordance with the phased approach to resuming currently suspended services encouraged by the Centers for Medicare and Medicaid Services (CMS).
** BLOG UPDATED 8/6/20: Due to COVID-19 concerns, CMS is going to expand the deadline for use of the renewed ABN, Form CMS-R-131. The renewed ABN will be mandatory for use on 1/1/2021.
The ABN, Form CMS-R-131, and form instructions have been approved by the Office of Management and Budget (OMB) for renewal. The use of the renewed form with the expiration date of 06/30/2023 will be mandatory on 8/31/2020.
HHS - Medicare
1. Have you completed Attestation Process via HHS website for Tranche 1, Tranche 2 and SNF Relief Fund Pmt?
2. Would you like for us to do this?
3. If yes, send the following info
- Tax ID Number
- Last 6 digits of Bank Account Number that money was deposited in
- Exact amount of Tranche 1 pmt, Tranche 2 pmt and - SNF Relief Fund Pmt
4. Sign the Attestation via the link: https://covid19.linkhealth.com/#/step/1
SUBMIT FINANCIAL DATA
1. Have you submitted Financial Data via HHS website? (Due by June 3, 2020)
2. Would you like for us to do this?
3. If yes, send the following info:
- Tax ID Number
- Last 6 digits of Bank Account Number that money was deposited in
- Exact amount of Tranche 1, Tranche 2 and SNF Relief Fund Pmt
- PD of most recently filed tax return to be uploaded
- Estimated Lost Revenue for March 2020
- Estimated Lost Revenue for April 2020
4. Submit your revenue information to be verified via the portal: https://covid19.linkhealth.com/#/step/1
TRACK HHS FUNDS
1. Do you want our assistance with HHS funds tracking?
2. Funds should be used on PREPARING, PREVENTING or RESPONDING to COVID-19
Contact us to learn more:
What is eligible for reimbursement?
HHS has distributed money to SNFs to help them combat the devastating effects of this pandemic. A very common question has been, “What expenses or lost revenues are considered eligible for reimbursement?”
The HHS.gov website has a shared a list of Frequently Asked Questions concerning the CARES Act Provider Relief Fund, including a response to this question on page 6.
Blog by Sarah McIntosh, Director of Operations
HHS Releases $4.9 billion in COVID-19 Relief for Skilled Nursing Facilities (SNFs)
SNFs received a baseline payment of $50,000, plus an additional $2,500 per bed.
As with other rounds of CARES Act funding, SNFs must agree to the terms and conditions in order to accept the cash.
SNF’s must also comply with future audit and reporting rules. Below is the link to the terms and conditions posted on HHS website.
Articles referencing Relief funds:
Small Business Administration (SBA) Payroll Protection Program (PPP)
Every borrower should begin preparing for the loan forgiveness process. Make sure that you are documenting how you spend you PPP proceeds and have proper documentation.
Below is a list of some information that will be needed:
• The number of full-time equivalent (FTE) employees on your payroll as of the following time periods
1. 8 week “covered period”
2. 2/15/19 to 6/30/19
3. 1/1/20 to 2/29/20
• Dollar amount of Payroll cost during the “covered period”
• Dollar amount of non-payroll cost incurred during the “covered period”
• Did you receive an SBA Economic Injury Disaster Loan (EIDL)
HHS Provider Letters
The Department of Health & Human Services recently sent letters to providers regarding submitting revenue data to the General Distribution Provider Portal for verification. The letter states “All providers, including those paid based on the revenue data already submitted in CMS cost reports, are required under the Terms and Conditions to submit revenue information to the General Distribution Provider Portal for verification.“
There has been much confusion if Providers are required to submit their revenue information. The provider letter states that ALL providers must submit their revenue information. Click here to view the Provider Letter.
Steps all Providers need to complete:
1. Sign the Attestation via the link: https://covid19.linkhealth.com/#/step/1
A. Tax ID number
B. Last Six Digits of Bank Account Number
C. Exact amount of the Relief Fund Payment
2. Submit your revenue information to be verified via the portal: https://covid19.linkhealth.com/docusign/#/step/1
A. Tax ID number
B. Last Six Digits of Bank Account Number
C. Exact amount of the Relief Fund Payment
D. Gross receipts of sales
a. Box 1a of IRS Form 1120
b. Box 1a of IRS Form 1120S
c. Box 1a of IRS Form 1065
d. Part I, 9 “Program Services Revenue” of IRS Form 990
E. Estimated Lost Revenue for March 2020
F. Estimated Lost Revenue for April 2020
G. Copy of IRS Form 1120 to upload
CARES Act Provider Relief Fund
President Trump is providing support to healthcare providers fighting the COVID-19 pandemic through the bipartisan CARES Act and the Paycheck Protection Program and Health Care Enhancement Act that provide $175 billion in relief funds to hospitals and other healthcare providers on the front lines of the coronavirus response. This funding supports healthcare-related expenses or lost revenue attributable to COVID-19 and ensures uninsured Americans can get testing and treatment for COVID-19.
Nursing Home Five Star Quality Rating System updates, Nursing Home Staff Counts, and Frequently Asked Questions
CMS is committed to taking critical steps to ensure America’s nursing homes are prepared to respond to the threat of the COVID-19.
Nursing Home Compare website & Nursing Home Five Star Quality Rating System: We are announcing that the inspection domain will be held constant temporarily due to the prioritization and suspension of certain surveys, to ensure the rating system reflects fair information for consumers.
Posting of surveys: CMS will post a list of the surveys conducted after the prioritization of certain surveys, and their findings, through a link on the Nursing Home Compare website.
Nursing Home Staff: CMS is publishing a list of the average number of nursing and total staff that work onsite in each nursing home, each day. This information can be used to help direct adequate personal protective equipment (PPE) and testing to nursing homes.
Frequently Asked Questions (FAQ): We are releasing a list of FAQs to clarify certain actions we have taken related to visitation, surveys, waivers, and other guidance.
CMS Reevaluates Accelerated Payment Program and Suspends Advance Payment Program
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.
See the latest news and updates from Governor Beshear.
MEDICAID PROVIDER LETTER
This memo from the Kentucky Department for Medicaid Services gives details for the following updates.
Effective April 1, 2020, Medicaid Rate add-on of $270 for COVID-19 positive patients.
Effective April 24, 2020, Medicaid is implementing a temporary process for Medicaid eligibility.
Effective April 1, 2020 Medicaid will be increasing the bed reservation days to 30 per calendar year through the state of emergency.
COVID-19 Emergency Circumstances LTC Bed Change Requests
As a result of the COVID-19 pandemic, CMS has demonstrated unprecedented flexibility to long-term care facilities in order to protect residents during the pandemic. CMS has released the “COVID-19 Long-Term Care Facility Guidance”, issued blanket waivers for certain CMS requirements of participation for LTC facilities, as well as offered flexibility regarding timeframes for COVID-19 emergency bed change requests. In response to the relaxed requirements offered by CMS and Governor Andy Beshear’s Executive Order 2020-215 declaring a state of emergency in the Commonwealth, a new bed change request process has been developed. The COVID-19 Emergency Circumstances LTC Bed Change Request Process allows for the faster processing of temporary bed change requests due to emergency circumstances related to the COVID-19 pandemic. This process waives all licensure and architectural review fees, allows for architectural desk reviews, removes the typical CMS timeframe requirements and eliminates the requirement for color coded floor plans when requesting certification status changes.
Emergency CMP Grant Project
It is with great pleasure that the Cabinet for Health & Family Services (CHFS) announces an emergency Civil Money Penalty (CMP) Grant Project opportunity for all certified nursing facilities within the Commonwealth. Specifically, CMS has notified the CHFS office that a grant program, Communicative Technology Project, has been approved to assist in alleviating communication limitations due to COVID-19. This grant program will allow Medicare-certified nursing facilities to apply for a CMP fund grant for up to $3,000 to cover the costs of certain communicative technology devices and accessories. More information can be found on the OIG Civil Money Penalty Funds website.
Department for Medicaid Services Update on Optional State Assessment
On March 19, 2020, CMS announced that changes to the Minimum Data Set (MDS) 3.0 v1.18.1 are being delayed, therefore, an Optional State Assessment (OSA) is not needed on October 1, 2020, as originally anticipated, in order to continue Resource Utilization Group (RUG) based Medicaid reimbursement.
We continue to expect that in the future, CMS will remove items from the MDS item set that are needed for maintaining RUG case mix reimbursement. As CMS modifies the items on the MDS assessments in the future, DMS will evaluate if OSAs will be needed to continue its RUG‐III reimbursement system. Communications regarding any future OSA requirement will be issued at that time. We will continue to publish information as it becomes available.
Should you have any questions, please contact Jacob Wilson at (502) 564-8196, extension 2103. Questions regarding the coding of the MDS assessments may be directed to Chrystal Daugherty, RAI Coordinator with the Office of Inspector General at 606-330-2030, extension 283.
A revision to the PDPM DLL Package (V1.0004 FINAL) was posted, and the previous version (V1.0003 FINAL) was removed. This version adds support for the new ICD-10-CM code for Coronavirus, U07.1. Note that this code is ONLY in effect for assessments with target date 04-01-2020 and later. The package contains updated test files and documentation.
Also, the lookup file for the allowable ICD codes in item I0020B has been updated to include U07.1, and it is posted as a separate ZIP file. Again, please note that this code is ONLY in effect for assessments with target date 04-01-2020 and later. The files are located in the Downloads section of the MDS 3.0 Technical Information site.
Audits are the new normal
CMS uses Comprehensive Error Rate Testing (CERT) audits to see if MACs are properly paying claims. CERT audits focus on logistical issues, such as whether or not the coding and billing are correct. CERT is looking for errors in payments made by carriers. Providers are affected because the CERT looks into a claim via Medical Records request. If the CERT uncovers an error, the CERT will recoup money from the provider. CERTs receive set amount outlined in their contract, regardless of the amount of payment errors they find.
Recovery Audit Contractors focus on errors created by the providers. The primary purpose of RAC is to detect and correct improper payments. RACs are paid through contingency fees (money they uncover). The contingency fee payment system encourages RACs to find errors.
Zone Program Integrity Contractors (ZPICs) are the most complex audits. ZPICs compare providers billing with similar providers. ZPIC reviews are not random. They are conducted under a presumption of fraud. ZPICs can be initiated by data analysis, frequency, whistleblowers or referred by MACs. Once an error is found they extrapolate the data in order to determine the amount of misappropriated funds.
Blog by Sarah McIntosh, Director of Operations
All DCBS offices are closed for appointments. Individuals may apply for Medicaid by calling the Kentucky Healthcare Customer Service line at (855)459-6328, visit the Benefind website (benefind.ky.gov) or by calling the DCBS Call Center at (855)306-8959.
During the COVID-19 State of Emergency, individuals who need special healthcare coverage should go to the kycovid19.ky.gov website and click on Services. The special healthcare coverage is temporary and ends on 06/30/2020 unless an application for regular Medicaid is submitted.
CARES ACT Provider Relief Fund to infuse $30 billion into healthcare system.
All facilities and providers that received Medicare fee-for-service (FFS) reimbursements in 2019 are eligible for this initial rapid distribution. These are payments, not loans, to healthcare providers, and will not need to be repaid. The payments should be arriving via direct deposit beginning April 10, 2020.
Fiscal Year 2021 Proposed Medicare Payment and Policy Changes
CMS projects aggregate payments to SNFs will increase by $784 million, or 2.3 percent, for FY 2021 compared to FY 2020.
Kentucky and Ohio Part A News from CGS
CGS is aware that certain eligible provider types may not have received the maximum eligible amount for their accelerated payment. We are identifying providers impacted by the 3-6 month max issue and determining a resolution. Please continue to monitor the CPIL for updates.
Kentucky Department for Medicaid Services Update on Cost Report Extensions
CMS has directed MAC's to further extend the cost reporting deadlines for the following cost reporting fiscal year ends (FYE) for all provider types:
Cost Reporting Period Ending -- Extended Due Date
10/31/2019 -- 06/30/2020
11/30/2019 -- 06/30/2020
12/31/2019 -- 08/31/2020*
01/31/2020 -- 08/31/2020*
02/29/2020 -- 09/30/2020*
*Please note, these are new extensions.
While we have been told that CMS is considering the 03/31/2020 FYE providers that are currently due 08/31/2020, no extension has been posted at this time.
The Advance Beneficiary Notice of Noncoverage
The Advance Beneficiary Notice of Noncoverage (ABN) Form CMS-R-131 is issued by providers to Original Medicare beneficiaries when Medicare payment is expected to be denied. Skilled Nursing Facilities (SNFs) issue the ABN to transfer potential financial liability for items/services expected to be denied under Medicare Part B only.
Form CMS-R-131, will expire 03/2020. The form is currently awaiting OMB approval for renewal. CMS will provide instructions when it does get approved. In the meantime, continue to use the current form until further instruction is provided.
CMS Flexibilities to Fight COVID-19
CMS is waiving 42 CFR 483.70(q) to provide relief to long term care facilities on the requirements for submitting staffing data through the Payroll-Based Journal system.
In this unprecedented time, our firm strongly recommends that all additional costs, related to COVID-19, be tracked separately from all other costs/departments. We recommend setting up a "new" department in your general ledger (financial statements) to track as many COVID-19 related expenses as possible. In these uncertain times, we want to be cautious and proactive. Facilities might have to verify the additional costs due to, but not limited, to the following.
Loans (SBA and others) - example: 8 week tracking period for SBA loan
Potential Medicaid additional add-ons (currently under discussions)
Below are examples of possible additional expenses:
Payroll - example: new staff hired for infection control, replacement workers for those sick, OT, additional labor for cleaning, hazard pay to maintain staff, etc.
Personal Protective Equipment (PPE) - masks, gloves
Screening costs for employees to enter the building
Cleaning supplies and additional costs for everyday supplies
Building retro fittings - example: putting in dividers to separate employees, staff, etc.
Please inform those responsible for your general ledger/financial statements. If you have any questions or need assistance, please contact our office.
Blog by Robin Parker, CPA, Sr. Accountant
IMPORTANT UPDATE: From UnitedHealthcare
Suspension of prior authorization requirements to a post-acute care setting through May 31, 2020. Details: Waiving prior authorization for admissions to: long-term care acute facilities (LTAC), acute inpatient rehabilitation (AIR), and skilled nursing facilities (SNF). Consistent with existing policy, the admitting provider must notify us within 48 hours of transfer and penalties still apply. Length of stay reviews still apply, including denials for days that exceed approved length. Discharges to home health will not require prior authorization. Prior authorization is not required for COVID-19 testing and COVID-19 testing related visits.
IMPORTANT UPDATE: From Anthem Blue Cross Blue Shield
Anthem is committed to working with and supporting providers. As of March 16, Anthem is removing prior authorization requirements for skilled nursing facilities (SNF) for the next 90 days to assist hospitals in managing possible capacity issues. SNF Providers should continue admission notification to Anthem in an effort to verify eligibility and benefits for all members prior to rendering services and to assist with ensuring timely payments. In addition, Anthem is also extending the length of time a prior authorization is in effect for elective inpatient and outpatient procedures to 90 days. This will help prevent the need for additional outreach to Anthem to adjust the date of service covered by the authorization. This applies to members of all lines of business, as well as self-insured plan members.
Kentucky Medicaid COVID-19 Information - Cabinet for Health and Family Services
The information on this page is specific to Medicaid beneficiaries and providers. For more information about COVID-19, refer to the state COVID-19 website.
UPDATE: KLOCS Training
More information will be provided when the new "go-live date" is determined and training forums are rescheduled. Thank you for your understanding as well as your continued commitment to keep your communities and residents safe.
COVID-19 CMS Medicare Waivers
Attention all Financial and Billing Staff
On March 13, 2020 the Centers for Medicare and Medicaid Services (CMS) issued a blanket waiver based on the declared public health emergency (PHE) COVID-19. This includes waivers for:
• 3 day qualifying hospital stay
• 60 day break in spell of illness. This extends an additional 100 day benefit period for residents who have recently exhausted Skilled Nursing benefits and must remain in a facility.
PointClickCare is currently in communication with CMS to clarify billing and MDS requirements surrounding these waivers. To prepare for monthly billing, review the COVID-19 Waiver Billing Quick Reference Guide (QRG).
PointClickCare is currently working to bypass the UB Edit Check of missing occurrence span code 70 Qualifying Hospital Stay or the demonstration code if DR is on the claim. Continue to monitor the Home Page for more information.
If your SNF needs assistance with this setup, please contact our office.
President Trump declared a national emergency on March 13, 2020. CMS issued Coronavirus 1812(f) waiver of the 3-Day Stay inpatient hospital requirement for Skilled Nursing Facilities (SNF). According to Administrator Verma’s press conference on March 13, 2020, the waiver takes effect retroactively to March 1, 2020. https://www.cms.gov/newsroom/press-releases/emergency-declaration-press-call-remarks-cms-administrator-seema-verma
For billing under this waiver, the Disaster Related (DR) condition code should be used by SNFs (institutional providers). The DR condition code is used at the claim level when all of the services billed on the claim are related to the emergency/disaster. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c38.pdf
PLEASE NOTE THAT AN ADMITTING RESIDENT MUST MEET SKILLED CRITERIA IN CHAPTER 8 OF THE MEDICARE BENEFIT POLICY MANUAL. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c08pdf.pdf
Hargis & Associates (H&A) places the health and safety of our clients, employees, and our health care community as our highest concern. As we continue to serve you, we are continuously monitoring the growing COVID-19 situation and those recommendations from World Health Organization (WHO) and the Center for Disease Control & Prevention (CDC).
At the present time, H&A has not experienced any interruption to our services or hours. We are encouraging all clients and employees to practice safe measures regarding health including cleaning for disinfection, hand washing, stay home if you are sick, limiting exposure, etc.
H&A is diligently reviewing all CMS and State guidance affecting health care coverage, billing and coding, and payment to our clients.
Please reference this CMS link for current guidance on these issues: https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current- Emergencies/Current-Emergencies-page
H&A recognizes the hardships you may be facing as a result of the COVID-19. We strive to continue to offer our services during these challenging times. If you find yourself needing assistance with billing or accounting functions due to staff shortages or the need to have all hands-on deck at your facility, please don’t hesitate to reach out to us for help. We are here to serve our elderly population every day and especially in times of crisis.
H&A will provide updates regarding the above to our clients and health care community through numerous avenues including publications at our office, our website, social media, etc. For more information or assistance visit our website or call our office.
PBJ & Credit Balance Reports
Staffing Data Submission Payroll Based Journal (PBJ)
Credit Balance Report (Form CMS-838)
A Medicare credit balance is an amount determined to b refundable to the Medicare program for an improper or excess payment made to a provider because of patient billing or claims processing errors. Each provider must submit a quarterly Credit Balance Report (Form CMS-838) If your facility has more than one provider number, a separate report should be submitted for each provider number. If you fail to submit a Credit Balance (CMS-838) form and/or certification page with all provider numbers identified, Medicare payments will be suspended as stated in 42 CFR 413.20(e) and 405.370. Providers with low Medicare utilization, as specified in the Provider Reimbursement Manual, CMS Pub. 15-1, Chapter 24 2414.4 B, or who file less than twenty-five Medicare claims per year, do not have to submit Form CMS 838. Providers that qualify should submit one, signed and dated certification page and a letter indicating that they are a low Medicare utilization provider. The following provides the reporting periods and associated due dates.
Quality Improvement Organizations (QIO)
Some nursing facilities have received a letter from Alliant Health Solutions and are questioning if Alliant is replacing KEPRO. KEPRO is the CMS Beneficiary and Family Centered Care – Quality Improvement Organization (BFCC-QIO) for Kentucky. KEPRO assist Medicare patients in exercising their right to appeal discontinued Medicare benefits. KEPRO remains to be Kentucky’s BFCC-QIO.
Alliant is CMS Quality Innovation Network – Quality Improvement Organization (QIN-QIO). The QIN-QIO is responsible for working with health care providers and the community on data-driven projects to improve patient safety, reduce harm and improve clinical care at the local level.
Blog by Sarah W. McIntosh, Director of Operations
Build a Better Bottom Line with Our Tax Solutions
Our Services - Tax
Manage your tax department with the knowledge needed to efficiently and effectively build a better bottom line with our tax solutions. Reduce the risk of overlooking tax credits and incentives. Hargis & Associates works for your business to identify opportunities resulting in optimal tax savings. We do the work for you; saving you time and resources.
Our dedicated and experienced staff successfully works with your team and the IRS during any tax auditing process. Faithfully rely on us to provide value-added insight.
A few Hot Topics in the news.
Publication of FY 2022 SNF Annual Payment Update (APU) Overview Table (Click here to read.)
CMS posts MDS 3.0 QM User’s Manual V13.0, Quality Measure Reporting Module Table V1.8 (Click here to read.)
2020 Physicians fee schedule has been revised (Click here to read.)
MACs will bypass the edit that requires an occurrence code 50 AND update the edit that ensures the default HIPPS code (Click here to read.)
Publication of FY 2022 SNF Annual Payment Update (APU) Overview Table
Article from Centers for Medicare & Medicaid Services (CMS)
CMS published the FY 2022 SNF Annual Payment Update (APU) table. This table indicates the data elements CMS will use for FY 2022 SNF QRP APU determinations. The SNF APU table is available in the document titled “FY-2022-SNF-QRP-APU-Table-for-Reporting-Assessment-Based-Measures-and-SPADEs-Finalized.pdf” in the Downloads section of the SNF Quality Reporting Program Measures and Technical Information webpage.
Coding for HIV/AIDS Patient
When billing Medicare A it is important to make sure you are checking your diagnosis when you have an HIV/AIDS patient. That diagnosis needs to be present on the claim in the first 9 diagnosis or you could miss that extra reimbursement. For example, a resident with HIPPS KAXD would be paid roughly $4500 for 9 days. With the AIDS NTA bump and Nursing addon, the reimbursement increases to $6,426.18.
Unlike other healthcare tax accounting firms, Hargis & Associates, LLC has a widely respected reimbursement team. We are dedicated to being on the forefront of the ever-changing financial climate. We understand the need for billing, training and accounts receivables management facing nursing facilities; that is why we ease the process through our advanced, healthcare billing department. With our proven billing services in place, clients improve cash flow by reducing days in outstanding accounts receivables.
Our Billing Services Include:
• Medicare A & B Billing
• Medicaid Billing
• Medicare Replacement/Managed Care Billing
• Medicare A and B Co-Insurance Billing
• Hospice Billing
• Filing of Medicare Credit Balance Report
• Medicare Bad Debt Log for Cost Report
• Online Billing Analysis, Rebilling, and Collections
• Posting of Cash receipts, adjustments, etc.
• Posting of Ancillary charges
• Accounts Receivable Analysis
• On-Site Training
• Billing Assistance Program
Blog by Leah Shoulders, Billing Manager
Updated Five-Star Ratings Released Today
Article from LongTermCareLeader.com
NHC is usually updated the fourth Wednesday of every month, but the updates on the first month of the quarter (i.e. January, April, July, October) are more noteworthy. They include updated quality and staffing data. Other monthly updates only include updated survey data.
- Quality Measure Data for 2018-Q4 to 2019-Q3 (Oct’18 – Sep’19) Released
- Payroll-Based Journal (PBJ) Staffing Data for 2019-Q3 (Jul’19 – Sep’19) Released
- Table of Expected Nursing Home Compare Releases with Updated Quality and Staffing Data in 2020
- Expect This Newer Data on LTC Trend Tracker Within a Week