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 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 by government health insurance programs or private insurers to continue getting free tests, treatments and vaccines.

HHS Secretary Xavier Becerra has stated that he will provide at least 60 days’ notice before ending the emergency that was first declared in January 2020. The declaration has since been renewed eight times. Many public health experts believe this could be the final extension. 

PROVIDERS NEED TO CONTINUE TO TRACK COVID-19 PHE COSTS

Many providers received Provider Relief Funds which have not yet been reported to HRSA.  Regardless of unreported COVID-19 PHE costs or not, we encourage providers to track expenses incurred as a result of the COVID-19 PHE.  Future PRF reporting deadlines are based on when funds were received.  Future reporting is as follows:

Funds                                            Deadline to                 Report
Received                                       Use Funds                   Due Date
01/01 – 06/30/2021                      06/30/2022                  09/30/2022
07/01 – 12/31/2021                      12/31/2022                  03/31/2023

DELAY IN APPROVAL AND FINALIZING CHANGE OF OWNERSHIP FILINGS CAUSE DIFFICULTIES FOR PROVIDERS

While we understand that we are currently in a period of a Public Health Emergency related to COVID-19, which began in January 2020, we have difficulty in understanding why CMS approval and Medicare Administrative Contractor follow-up of Change of Ownership (“CHOW”) applications, in many instances, is taking such a long period of time.  Recently, two simple CHOWs which occurred in 2019 were finally approved.  We are aware of several CHOWs, which also occurred in 2019 and 2020, that remain outstanding for approval. There appears to be no reasoning for such a delay, COVID-19 PHE or not.  These delays can cause significant disruption to the ongoing activities of the provider and add costs to the provider, both during the period of review and once the delinquent approval is received.  We encourage providers to bring national and state associations up to date on any such significant delays thereby potentially allowing them to advocate for timely enrollment update processes.

MedPAC REPORT AVAILABLE

The Medicare Payment Advisory Commission (“MedPAC”) released its Report to Congress on March 15, 2022.  We encourage all providers to review the report or at least the Chapter relevant to your activities.  The report is intended to evaluate Medicare payment issues and make recommendations to the Congress.  The report is available here.