Volume 24.01 The Centers for Medicare & Medicaid Services (“CMS”) has continually been concerned regarding how to identify “bad actors”, their continued involvement with Medicare providers, and the appropriate response to inappropriate behavior by providers,...
CMS RELEASES MEDICARE ENROLLMENT APPLICATION FEE FOR 2024
Volume 23.08 CMS has announced a $709 calendar year application fee for providers that are: Initially enrolling in the Medicare program, Medicaid program, or the Children’s Health Insurance Program (“CHIP”), Revalidating their Medicare, Medicaid, or CHIP enrollment,...
CMS MOVES ON ADDITIONAL OWNERSHIP DISCLOSURES FOR NURSING FACILITIES
Volume 23.07 On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) placed on display at the Federal Register a Final Rule that will implement portions of section 6101 of the Affordable Care Act, requiring the disclosure of certain ownership,...
MEDICARE ENROLLMENT PROVISIONS INCLUDED IN PHYSICIAN FEE RULE FINALIZED
Volume 23.06 The Centers for Medicare and Medicaid Services (“CMS”) has finalized the CY 2024 Medicare Physician Fee Schedule rule. Many enrollment-related provisions were included in the proposed rule. The Health Group, LLC discussed the proposed rule at its...
IRS ANNOUNCES WITHDRAWAL PROCESS FOR EMPLOYEE RETENTION CREDIT CLAIMS
Volume 23.05 Many healthcare providers, for-profit and tax-exempt, submitted claims to secure the Employee Retention Credit based on lost revenues; however, many submitted claims based on other criteria related to the issuance of government orders. These claims,...
PROCESSING TIME FOR MEDICARE ENROLLMENT APPLICATIONS – AN INCREASING PROBLEM FOR PROVIDERS
Volume 23.04 Many providers are dealing with significant delays in processing Medicare enrollment updates and new enrollment applications. It is not unusual to see approvals of CMS 855 filings taking four months to a year. Change of ownership and new enrollment...
NUMEROUS PROVIDER ENROLLMENT CHANGES INCLUDED IN THE MEDICARE PHYSICIAN FEE SCHEDULE PROPOSED RULE
Volume 23.03 CMS’s increasing focus on provider integrity continues as they have proposed numerous Medicare enrollment changes impacting healthcare providers of all types. The proposed rule includes, but is not limited to, the following: Reporting Changes in Practice...
MANY HEALTHCARE PROVIDERS AT RISK FOR IRS RECOVERY OF ERC CREDITS
Volume 23.01 On March 7, 2023, the IRS issued a warning to Employee Retention Credit claims. False claims generate compliance risk for people and businesses claiming improper credits. According to the warning, “The IRS and tax professionals continue to see third...
CMS UPDATES MEDICARE ENROLLMENT INSTRUCTIONS
Volume 22.12 Effective December 5, 2022, certain modifications have been made to Chapter 10 of the Medicare Program Integrity Manual dealing primarily with “Ownership Disclosures”, “Electronic Funds Transfers”, and “Special Payment Addresses”. MM12880 - Provider...
OIG REPORTS ON PROVIDER RELIEF FUND REQUIREMENT IMPROVEMENTS
Volume 22.11 In September 2022, the Department of Health and Human Services Office of Inspector General (“OIG”) released a report entitled “HHS’s and HRSA’s Controls Related to Selected Provider Relief Fund Program Requirements Could Be Improved” (“Report”). The...
MAJOR REVISIONS MADE TO HOME OFFICE COST REPORT
Volume 22.10 The U.S. Centers for Medicare & Medicaid Services has released Home Office Cost Statement, Form CMS-287-22 (“Home Office Cost Report”). R1P248i | CMS The new Home Office Cost Report (CMS-287-22) is effective for cost reporting periods beginning on or...
REPAYMENT AND RECOVERY OF COVID-19 CAAP
Volume 22.09 In March 2021, CMS began recovering COVID-19 Accelerated and Advance Payment (“CAAP”) balances. After one year, the recovery of the advanced monies was made at twenty-five percent (25%) over eleven months, followed by fifty percent (50%) over the...
OIG EXCLUSION LIST UPDATED
Volume 22.08 The Office of Inspector General (“OIG”) has the authority to exclude individuals and entities from Federally funded health care programs pursuant to section 1128 of the Social Security Act ("Act") (and from Medicare and State health care programs under...
CMS REVALIDATION LIST MAY NOT BE UP TO DATE
Volume 22.07 Medicare providers are required to revalidate information contained in the Medicare enrollment records on a periodic basis to ensure all information on file is accurate and compliant with Medicare regulations. Revalidation was paused because of the...
DEACTIVATION OF MEDICARE BILLING PRIVILEGES DUE TO LACK OF BILLING
Volume 22.06 For several years we have cautioned health care providers that Medicare billing privileges could be deactivated if the provider did not submit any Medicare claims for twelve (12) consecutive months. This deactivation is provided for at 42 CFR...
HEALTH CARE FRAUD AND ABUSE CONTROL PROGRAM FY 2021 REPORT ISSUED
Volume 22.05 The Department of Health and Human Services and the Department of Justice have released the Health Care Fraud and Abuse Control Program Annual Report for Fiscal Year 2021. During FY 2021, the federal government won or negotiated more than $5 billion in...
COVID-19 PHE EXTENDED AGAIN
Volume 22.04 The Biden administration on Wednesday extended the COVID-19 public health emergency that had been due to expire on April 16. The 90-day extension, announced by the Department of Health and Human Services (HHS), will allow millions of Americans covered...
REPORTING FOR USE OF PROVIDER RELIEF FUNDS
Volume 22.03 Many providers are confused regarding the required reporting for the use of Provider Relief Funds (“PRF”). Reporting timelines are based on when the funds were received by the provider. The following summarizes when funds must be used and reported to...
CHANGING HEALTHCARE COSTS AS A RESULT OF COVID-19 PHE AND THE AFTERMATH
Volume 22.02 Many healthcare providers, consultants to the healthcare industry, and other observers have been attempting to gain an understanding of the changes to the healthcare delivery systems and the changes in costs incurred by healthcare providers, which may...
SUPREME COURT ALLOWS MANDATORY VACCINATIONS FOR HEALTH CARE PROVIDERS
Volume 22.01 On Thursday, the Supreme Court issued mixed rulings, allowing vaccine mandates for certain health care workers (Vote was 5-4), but blocking enforcement of a mandate for businesses with 100 or more employers (Vote was 6-3). The Court ruled that OSHA lacked...
MEDICARE SEQUESTRATION DELAYED AND REDUCED IN LEGISLATION
Volume 21.15 The U.S. Senate is expected to pass legislation (already passed in the House of Representatives) that would: Implement an additional three (3) month suspension of the two percent (2%) Medicare sequestration payment reductions that were scheduled to begin...
CMS ISSUES EMERGENCY REGULATION REQUIRING COVID-19 VACCINATIONS
Volume 21.14 CMS is issuing an Interim Final Rule requiring most Medicare and Medicaid certified providers and suppliers to establish a policy ensuring that all eligible staff have received the first dose of a two-dose vaccine or a one-dose vaccine prior to providing...
PROVIDER RELIEF FUNDS – PHASE 4 APPLICATION SUBMISSION TIMING MODIFIED
Volume 21.13 Over the weekend, the Health Resources and Services Administration (“HRSA”) modified certain details regarding the Phase 4 PRF application. Information provided by HRSA now requires Phase 4 applicants to submit their Taxpayer Identification Number...
PHASE 4 OF PROVIDER RELIEF FUNDING REQUIRES AN IRS VALIDATION
Volume 21.12 If you are going to apply for Phase 4 funding of Provider Relief Funds and have not yet applied for IRS validation, you should immediately submit required, but limited, information for IRS validation. This process must be completed before you can upload...
PROVIDER RELIEF FUND (PHASE 4) UPDATE
Volume 21.11 Providers can apply for the new, Phase 4, Provider Relief Funds beginning September 29, 2021. The application period will run through October 26, 2021. The application will be made in the Provider Relief Application and Attestation Portal. Providers...
USING YOUR BUDGET FOR CALCULATING LOST REVENUES FOR PRF REPORTING
Volume 21.10 Three methods are available to healthcare providers for determining lost revenues eligible to be applied as a qualified use of Provider Relief Funds. These are: Option 1: Actual 2020 and 2021 revenues compared against 2019 revenues, Option 2: Actual 2020...
PHASE 4 COVID-19 PHE PROVIDER FUNDING
Volume 21.06 HHS Press Release: “The Biden-Harris Administration announced today that the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), is making $25.5 billion in new funding available for health...
WILL ALL HEALTH CARE PROVIDERS BE REQUIRED TO MANDATE COVID VACCINATIONS?
Volume 21.05 It is reported that the U.S. Centers for Medicare & Medicaid Services (“CMS”) and the Centers for Disease Control and Prevention (“CDC”) are jointly involved in the development of changes in Conditions of Participation that would require all staff of...
RULES FOR SINGLE AUDITS OF NONFEDERAL ENTITIES UPDATED TO ADDRESS PRF
Volume 21.09 The Department of Health and Human Services (“HHS”) has updated the rules relating to the reporting of Provider Relief Funds (“PRF”) use by nonfederal entities as part of the single audit requirements. Recipients that expend a total of $750,000 or more in...
MEDICARE ENROLLMENT UPDATES
Volume 21.08 CMS has temporarily ceased revalidations for Medicare providers and suppliers because of the COVID-19 PHE. CMS is not issuing any revalidation notices, deactivating providers for any failure to respond to revalidation requests and is not updating...
LONG AWAITED UPDATES TO PRF REPORTING DATES
Volume 21.07 The U.S. Department of Health and Human Services (“HHS”) has released updated reporting requirements for the use of Provider Relief Funds (“PRF”). The period of availability of funds is based on the date the payment is received (rather than requiring all...
COVID-19 ACCELERATED AND ADVANCE PAYMENT REPAYMENTS
Volume 21.06 In 2020, the U.S. Centers for Medicare & Medicaid Services (“CMS”) expanded the availability of Accelerated and Advance Payments to Medicare providers to provide assistance with cash flow during the COVID-19 Public Health Emergency (“PHE”). CMS has...
COVID-19 PHE AND MEDICARE COST REPORTS
Volume 21.05 We previously reported regarding the impact of the COVID-19 PHE and Medicare cost reports; however, based on numerous inquiries, we are pleased to provide the following information. Filing Deadlines – For cost reports covering periods through December 31,...
New Audit Requirements for Cares Act – Provider Relief Funds
Volume 21.04 The financial assistance received by many healthcare organizations in 2020 was not free of compliance requirements. As most of you know by now, The Department of Health and Human Services (HHS) is requiring the recipients of payments in excess of $10,000...
CLARIFICATION ON USE OF PRF TO REPAY MEDICARE ADVANCE PAYMENTS
Volume 21.03 On October 8, 2020, CMS issued a Press Release announcing that COVID-19 Provider Relief Funds (“PRF”) could be used to repay obligations incurred because of the Accelerated and Advance Payment program. We have received numerous inquiries regarding this...
CARE FUND REPORTING PORTAL OPEN FOR REGISTRATION
Volume 21.02 As you probably know, earlier today the Health Resources & Services Administration (“HRSA”) has opened the Provider Relief Fund Reporting Portal for registration, but not for reporting the use of Provider Relief Funds (“PRF”). Reporting has again...
COST REPORTING UPDATES COST REPORT EXTENSIONS
Volume 21.01 On January 5, 2021, CMS has updated the list of cost report filing extensions as follows: For all cost reports with cost reporting periods ended on March 1, 2020 through December 31, 2020, providers are granted an additional sixty (60) days from the...
CONSOLIDATED APPROPRIATIONS ACT OF 2021 (OMNIBUS AND CORONAVIRUS RELIEF BILL)
Volume 20.40 The Omnibus and Coronavirus Relief Bill was passed by Congress on December 21, 2020. The Bill, over 5,000 pages, titled The Consolidated Appropriations Act, 2021 (Omnibus and Coronavirus Relief Bill) will directly or indirectly impact every part of the...
CAN LOST REVENUE FROM FUNDRAISING BE CHARGED TO PRF?
Volume 20.39 There has been substantial confusion throughout the healthcare industry regarding expenses and lost revenues which will be eligible for justification of Provider Relief Funds. With every update from the U.S. Department of Health and Human Services...
WILLIAM T (“Ted”) CUPPETT TO PRESENT FOR HEALTH FINANCIAL SYSTEMS
Volume 20.38 Health Financial Systems (“HFS”) will be holding its virtual 2020 User Meeting on December 7-10, 2020. Ted Cuppett will be presenting on Wednesday, December 9, 2020 on “Preparing for Reporting the Use of Provider Relief Funds”. The summary of program...
CMS FINALIZES RULES INTENDED TO UPDATE PHYSICIAN SELF-REFERRAL REGULATIONS
Volume 20.37 Section 1877 of the Social Security Act ("the Act"), also known as the physician self-referral law or “Stark Law” prohibits: A physician from making referrals for certain designated health services (“DHS”) payable by Medicare to an entity with which he or...
PPP LOAN FORGIVENESS TAX IMPACT WILL BE IN 2020
Volume 20.36 Many healthcare providers are taxable entities and secured PPP loans. These providers, like other businesses, were taken off guard when the IRS determined that qualifying expenses would not be deductible once loan forgiveness was secured. Additionally,...
PROVIDERS NEED TO PREPARE NOW FOR REPORTING USE OF PROVIDER RELIEF FUNDSPROVIDERS NEED TO PREPARE NOW FOR REPORTING USE OF PROVIDER RELIEF FUNDS
Volume 20.35 The Department of Health and Human Services (“HHS”) has released updated guidance on reporting the use of Provider Relief Funds (“PRF”). The updates provide some clarification regarding the upcoming reporting. Providers can follow their normal accounting...
REPAYMENT TERMS FOR MEDICARE ADVANCE PAYMENTS MODIFIED
Volume 20.34 CMS successfully paid more than 22,000 Part A providers, totaling more than $98 billion in accelerated payments. This included payments to Part A providers for Part B items and services they furnished. In addition, more than 28,000 Part B suppliers,...
ADDITIONAL MEDICARE PROVIDER ENROLLMENT SCRUTINY
Volume 20.33 While healthcare providers deal with the COVID-19 PHE, preparing to deal with HHS reporting on the use of Provider Relief Funds, and many other ongoing issues, silently on May 22, 2020, CMS rolled out Transmittal 10146, which completely reorganized...
PROVIDER RELIEF FUNDING PHASE 3
Volume 20.32 The U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), has announced $20 billion in new funding for providers on the frontlines of the coronavirus pandemic. Under this Phase 3 General...
PROVIDER RELIEF FUND REPORTING REQUIREMENTS RELEASED
Volume 20.31 HHS has finally issued general reporting requirements for the use of Provider Relief Funding. This document provides information on provider reporting guidelines, including intent, use of funds, and data elements requested. The purpose of the notice is...
HHS REPORTING FOR USE OF CARES ACT PROVIDER RELIEF FUNDING?
Volume 20.30 Previously, the U.S. Department of Health and Human Services (“HHS”) issued Notice of Reporting Requirements relating to the use of Provider Relief Funds. HHS informed providers that forms would be available in mid-August 2020 and would be required for...
CMS RELEASES GUIDANCE ON CERTAIN COVID-19 PHE RELATED ITEMS ON COST REPORT SUBMISSIONS
Volume 20.29 On August 26, 2020, CMS issued an update on COVID-19 Frequently Asked Questions (FAQs) on some cost report issues. The following summarizes current CMS guidance. Reporting Provider Relief Funding – All providers are to report funding provided on the...
COMPLIMENTARY WEBINAR – CONSOLIDATION IN HOME HEALTH & HOSPICE: KEY TRANSACTIONAL CONSIDERATIONS
Volume 20.28 Tomorrow at 1:00 p.m. (Thursday, August 13, 2020), Provider Healthcare Partners, along with The Health Group, LLC will be hosting a complimentary webinar on issues relating to home health and hospice mergers and acquisitions.