HHS Announces New Opportunity to Apply for Provider Relief Fund Resources

On October 1, 2020 the Department of Health and Human Services (HHS) announced a new opportunity for providers to seek funding through the HHS Provider Relief Fund.  HHS will be accepting applications from October 5, 2020 through November 6, 2020.
 
What It Means
Congress allocated $175 billion to HHS for the CARES Act Provider Relief Fund.  As of September 24, HHS had allocated $122.9 billion of those funds. That funding has been divided between:

• General distributions: two General Distributions - Phase 1 ($50 billion) and Phase 2 ($18 billion) - distributed through a combination of proactive distributions and application-based awards, and,
• Targeted Distributions: proactive distributions to specific provider types - primarily hospitals and nursing homes

Today, HHS has allocated an additional $20 billion for another General Distribution, which they have deemed "Phase 3 General Distribution."
 
HHS encourages providers to apply early

The new distribution methodology will take into account other applicants, so HHS will not be able to calculate full awards until it has received and reviewed all applications. 

 

NOTE: Application access is not yet available, but will be posted on the CARES Act Provider Relief Fund webpage when available.

 

Virtually all health care providers should be eligible to apply for funding in this distribution.  Even those providers who received funding previously may be newly eligible for consideration.  

Key parameters of the new distribution
The new distribution is application-based. Interested providers will be required to apply as opposed to receiving a proactive distribution from HHS. HHS will accept applications from October 5 through November 6.

The application will be open to: 

• Providers who have previously received, accepted, or rejected funding through the Provider Relief Fund,
• Behavioral health providers (some had previously been excluded for methodological reasons), and
• Providers newly practicing in 2020 (previously excluded for methodological reasons).

Distribution methodology

Two percent of Patient Care Revenue - HHS will review each application to ensure providers have received two percent of their annual patient care revenue, taking into account previous distributions from the Provider Relief Fund.  This methodology is consistent with the most recent General Distribution Phase 2, for which applications closed on September 13.

 

"Equitable Add-On Payment" - HHS indicates it will use the remainder of the $20 billion (after ensuring all applicants have 2% of annual patient care revenue) to calculate an "equitable add-on payment" for all applicants, reflecting:

• A provider's change in operating revenues from patient care,
• A provider's change in operating expenses from patient care, including expenses incurred related to coronavirus, and
• Payments already received through prior Provider Relief Fund distributions.

For updates and to learn more about the Provider Relief Program, visit: hhs.gov/providerrelief.

 

President Trump Signs into Law Continuing Appropriations Act, 2021 and Other Extensions Act

On October 1, 2020 President Trump signed into law H.R.8337: Continuing Appropriations Act, 2021 and Other Extensions Act. The Senate passed the bill last night by a vote of 84-10 and the House passed the same measure last week by a vote of 359-57-1.  

This continuing resolution (CR) provides continued FY2021 appropriations to federal agencies through December 11, 2020 and extends several programs. Of particular interest to our sector, this bill modifies the Accelerated and Advance Payment Programs under Medicare parts A and B during the COVID-19 pandemic. Below are specific details of the modifications.

Congress changed the terms of loan repayment in the following ways: 

• Subsection C of the bill makes clear that Part A providers, in addition to hospitals now have an extension from 120 days of the loan to 29 months from the date of the first payment.
• One year delay - Repayments for both Part A and Part B providers will not begin until at least a year from the date of the original payment from CMS.
• Staggered recoupment - Rather than seizing the entire amount of claims until that is repaid, CMS would put limits on the total amount deducted from new claims during the recoupment period:
  • During the first 11 months in which any such payment offsets are made, 25 percent of the amount is due.
  • During the succeeding 6 months, 50 percent of the amount is due.
• Longer recoupment period - Providers would have 29 months from the date of the first Advance/Accelerated payment to repay funds before a bill is sent for the balance, including interest.
• Lower interest rate - The legislation would lower the interest rate for payments due after the recoupment period from ten percent to four percent.  
  

However, Congress is also sending a message back to CMS with the legislation. The CR would cap the total amount of funds CMS can issue through Advance/Accelerated payments under Part B to $10 million per year. The legislation also calls for additional reporting from CMS about the payments disbursed and tracking recoupment. Democratic committee leadership expressed concern with the fact CMS issued payments without Congressional input.

 

Wage Increase Extended to December 2020

The recently passed Michigan budget for FY 2021 included an extension to the $2 Wage Increase that was in place from July - September 2020.  The program will continue to operate as the prior program.  Below are the changes added to the updated FAQ on this program.  Requests for reimbursement for the July-September program must be filed by October 23rd and should not include any information for hours related to the new program effective October 1, 2020.  Request for reimbursement for hours October 1 to December 31, 2020 should be filed on a separate form and will be processed the same as the prior program.  The October 1 program hourly wage is measured against the wage in place on October 1 which differs from the prior program.

Will the direct care worker wage increase continue past September 30, 2020?

1. Has the direct care worker wage increase been extended?
   Yes, the direct care worker wage increase has been extended through December 31, 2020.
   
   
2. Has the reimbursement process changed?
   No, the process for requesting reimbursement remains the same. The only difference is that requests for reimbursement for eligible employee hours and payroll tax expenses between July 1 through September 30 must be submitted on separate forms from requests for the October 1 through December 31 period.
   
   
3. Have there been any changes to who is entitled to the wage increase?
   No, the employees eligible for the wage increase remain the same.
   
   
4. Have there been any changes to the eligible employee hours and payroll tax expenses? Are there additional eligible employee expenses?
   The eligible employee hours and payroll tax expenses remain the same, and there are no additional eligible employee expenses.
   
   
5. Has the wage level the direct care wage increase is compared to changed?
   Yes, the wage level the direct care wage increase is compared to is the wage that would have been in effect on October 1, 2020 had the direct care wage increase expired (i.e., if an employee had a base wage of $15/hour from July 1 through September 30 and was scheduled for a base wage increase to $16/hour on October 1, then the employee should receive $18/hour).
   
   
6. Is there a deadline for submitting direct care worker wage increase reimbursement requests?
   Requests for hours worked between July 1 through September 30 must be submitted no later than October 23, 2020. There is currently no deadline for requests for hours worked between October 1 through December 31, but this may be subject to change.

Medicaid Rates Released

The Michigan Department of Health & Human Services (MDHHS) has released the Medicaid rates effective October 1, 2020.  Below is an excerpt from the notice sent to providers regarding these rates and how to access them.

 

The notices are now available to providers, by accessing MILogin and entering the CHAMPS application.  The above reimbursement rate calculation and notice can be located under the "Archived Documents" section for each provider under the provider's National Provider Identification (NPI) number.

Trouble accessing MILogin, or Archived Documents please contact Medicaid Provider Support at ProviderSupport@michigan.gov OR call (800) 292-2550.

 

Questions regarding your provider specific reimbursement rate calculation  notice  should be directed to:  LTC Reimbursement and Rate Setting Section at DARS@michigan.gov or call (517) 335-5356. 

 

Updated SNF QRP COVID-19 PR Tip Sheet is Available

An updated version of the Skilled Nursing Facility (SNF) COVID-19 Public Reporting (PR) Tip Sheet that was posted on September 8, 2020, is now available. The purpose of this Tip Sheet is to help providers understand the Center for Medicare & Medicaid Services (CMS) public reporting strategy for the Post-Acute Care Quality Reporting Program (PAC QRP) in the midst of the COVID-19 public health emergency (PHE).  This Tip Sheet explains the CMS strategy to account for CMS quality data which were exempted from public reporting due to COVID-19, and the impact on CMS' Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) data on the Nursing Home Compare website refreshes.  Given the exempted data, CMS will complete a normal refresh for October 2020 and then freeze upcoming quarterly refreshes until January of 2022.  The updated Tip sheet is available HERE. 

 

AHCA/NCAL Quality Award Program Implementing One Year Extension of Eligibility

The AHCA/NCAL National Quality Award Program is pleased to announce the approval of an automatic one-year extension for recipients in their third year of renewal. The Program is making this extension in order to be supportive of members during these challenging times and offering them the opportunity to maintain their active status even if they are not able to apply in 2021.

This means that recipients in their third year of renewal in 2021 will have one more year (2022) to remain active and apply at the next award level. There is no action needed on the part of the recipient to receive the extension. Members in their third year of renewal are still able to apply during the 2021 award cycle. The intent to apply deadline for 2021 is November 12, 2020 at 8 PM EST.

The Renewal Policy, previously known as the Recertification Policy, has been updated to allow recipients additional options to stay active. To learn more about the Renewal Policy, visit the National Quality Award website.

 

Superior Health Quality Alliance

Superior Health Quality Alliance's Nursing Home Quality Improvement Collaborative expands on years of experience assisting nursing homes with improving the quality of care and the quality of life of people living in nursing homes.  Superior Health is the Centers for Medicare & Medicaid (CMS) designated Quality Improvement Organization (QIO) covering Michigan, Wisconsin & Minnesota. 

We encourage member facilities to consider joining the Superior Health Nursing Home Quality Collaborative to prevent infections, improve quality scores, train staff, access data and improve resident health. Participation is flexible and tailored to your needs. The enrollment period is ending soon. For more information contact info@superiorhealthqa.org.

 

 

For questions or concerns please contact Cathy Sunlin at CathySunlin@HCAM.org.

 

 

October 2, 2020