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Webinar: HHS Reporting Requirements

w/Asbel Montes

January 14, 2021

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Webinar: COVID-19 Vaccinations

w/Asbel Montes

December 1, 2020

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Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

June 17, 2020

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Questions and Answers Transcript

Has there been any further clarification about billing the HRSA Covid-19 Uninsured program for presumptive patients?


It was always under the assumption that presumptive and positive we're going to be paid. But unfortunately, that terms and conditions that you sign is for positive patients.

It has not been clarified right now. Currently, It is for positive only. There are additional avenues available for reimbursement for uninsured patients but that would be an effort at the state and local level.




Aside from HHS or PPP what other forms of relief should we be looking into?


There are 3 buckets of funding available: Payroll Protection Program, CARES Act Funding and FEMA. The CARES Act funding has a few avenues available: (1) distributions through Health & Human Services (HHS), as well as distributions through the Coronavirus Relief Fund (CRF). The CRF funds are distributed directly to state and local governments by the U.S. Treasury. These funds are available for loss revenue and increased expenses related to the Public Health Emergency. You will need to work with your state government and/or local jurisdictions to get access to these funds.




How long do we have to submit bills for uninsured COVID?


Until they run out of money and the public health emergency is over. We haven't been notified yet that they ran out of money... I would keep submitting your claims until they tell you there's no more money left available.




If we were denied for the second wave of HHS funding, can we still apply for the third wave?


I'm assuming when you mean denial that the formulary had you as a negative, so that's not really a denial. If that is what you are referencing, it just means that you did not qualify for a second level because the formula funding saw that you had already received a substantial amount of money based upon the formulary that was put together (i.e. 2% of that net operating revenue number based upon your tax filings or your balance sheet and that you uploaded your audited financials). Technically, yes, you would apply. From what I understand, it's going to be another application process.




Is there an update regarding HHS uninsured funding applying to only uninsured?  I wonder about the time period for submitting those claims and receiving dedicated funds.  Areas of the country are currently seeing spikes.


Right now, the uninsured funding is only available to those uninsured. When you read the terms and condition, you have to verify that they have no other insurance source. And, according also to Terms and Conditions you signed, it's only available to positive COVID patients. As of right now, there is no end date on that. Basically, as long as there's funds available, they are going to reimburse for the uninsured COVI-19 positive patients.




Is there any stimulus money for additional cost that we have incurred due to Covid-19?  If so, how do we apply for them?


In the next allocation, you'll see the application process open up. We're not really sure yet what the formulary is. We do understand that it is going to be looking at increased expenses aound the PPE area. Also an update to your lost revenue numbers, because you only recorded March and April and we're now into June.




Since we provided March/April lost revenue re the CARES Act, does this mean we are prohibited from claiming lost revenue from other government reimbursement sources? If so, can we seek lost revenue for other months from the Feds?


You need to have a formalized documentation system that is keeping track of all funding received due to the Public Health Emergency. This could be funding received from the Paycheck Protection Program, FEMA, HHS and any funds received from state or local government related to the PHE. Once the PHE is rescinded, you will then need to compare your lost revenue and increased expenses throughout the PHE to the revenue you received from all sources. If you have received more revenue, you will need to reimburse the federal government. If you have receive less revenue from federal sources compared to your lost revenue and increased expenses, then you will not be required to refund the federal government. Documentation will be key! Document, document, document!




When are the first CARES Act quarterly reports due?  Are there any published report specifications and requirements?


Currently, the only requirement is to submit your financial statements via the attached portal. If you have already done this through Tranche 2 funding, then nothing is due at this time. If you did not complete the application for Tranche 2 funding, you will need to follow the instructions as indicated.

https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html




When will be get notified if we will receive money under Tranche 2 of HHS?


You should have been notified already. If not, please call (866) 569-3522.




Will any part of the funding provided to state and local governments under the US Treasury Coronavirus Relief Fund (i.e. the $1.25 billion minimum to each state) eventually be allowed for revenue replacement?


Currently, the CARES Act direction is specific on what state and local governments can use these funds for.

The guidance clarifies what costs are permissible under the CRF, noting that necessary expenditures incurred due to the public health emergency:

  • Must be used for actions taken to respond directly to the COVID-19 public health emergency
  • May include expenditures incurred to address medical or public health needs, as well as to respond to second-order effects of the emergency, such as providing economic support to those suffering from employment or business interruptions
  • Can’t be used to fill shortfalls in government revenue to cover expenditures that wouldn’t otherwise qualify under the statute

Only certain costs not accounted for in the government’s budget most recently approved as of March 27, 2020 are permitted. Costs will, however, meet the above requirement if the cost:

  • Can’t lawfully be funded using a line item, allotment, or allocation with that budget
  • Is for a substantially different use from any expected use of funds in such a line item, allotment, or allocation

A cost isn’t considered to have been accounted for in a budget merely because it could be paid from a budgetary stabilization fund, rainy day fund, or similar reserve account.




Will the Medicare sequestration roll back be permanent or will the 2% be back?


The Medicare sequestration roll back is temporary only and expires on 12/30/2020. It remains to be seen if Congress will make this permanent or not.




Will the Round Two Cares Act Application Portal open up again? We didn't have enough time to complete the application and want additional funding.


Round Two closed on 6/3/2020. HHS will be doing a Round 3 funding soon.




Any updates on auditing or reporting - can we just claim a revenue loss based on call volume or do we also have to show what the money was spent on?


Based upon the FAQ posted on 6/13/2020 via https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html. See the following:

Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision. For all providers who attest to receiving a Provider Relief Fund payment and agree to the Terms and Conditions (or retain such a payment for more than 90 days), HHS is posting the names of payment recipients and their payment amounts on its public website Tracking Accountability in Government Grants System (TAGGS). HHS is also working with the Department of Treasury to reflect the aggregate total of each recipient's attested to Provider Relief Fund payments on USAspending.gov. Posting these data meets the reporting requirements of the CARES Act. See Appendix A of OMB Memo M-20-21 - PDF [Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19)].

However, the Terms and Conditions for all Provider Relief Fund payments also require recipients to submit any reports requested by the Secretary that are necessary to allow HHS to ensure compliance with payment Terms and Conditions. HHS will be requiring recipients to submit future reports relating to the recipient's use of its PRF money. HHS will notify recipients of the content and due date(s) of such reports in the coming weeks.




We have never had to submit Cost Data for Novitas, but understand it is a requirement due to the HHS funding. What format do we submit it in and where?


Please see answer above.




Traunch 3 includes all providers, including hospitals?


They're indicating it is a general allocation. And if it's a general allocation, then it would include everybody. Do not hold me to that. Remember, this is what they were thinking. They could make it a little bit more specific because the hospitals have been receiving a ton of money. And many of you have been probably talking to some of your hospital colleagues and some of them are actually sending money back because they've got way too much that they can't justify, especially in areas that may not have been hotspots that right now, if it is a general allocation, it would include all suppliers and providers of health care.




Could you please talk about the application due July 20th for the upcoming $15B HHS allocation for agencies participating in Medicaid and CHIP?


If you received funding in Round 1 or Round 2, you will not be eligible for the Medicaid and CHIP funding.




Are there any tax implications for the CARES ACT funds?


I'm going to tell you to get with your tax advisor on that. That is not my area of specialty. And there are depending upon how you have set yourself up. But I would definitely get with your tax advisor on that.




We teach EMT classes. Do these lost revenues count?


Anything related to the provision of healthcare that's related to the corona virus and pandemic would qualify. If you teach EMT classes and that was a source of revenue and because of the pandemic, you've seen a loss of EMT. And so you've seen a loss of revenue related to that. That would be a justifiable revenue loss.




If a patient becomes retroactive with Medicaid and we already received payment from the Uninsured Program - how do we go about contacting HRSA for refunds?


If at the time you validated and checked for insurance, and the patient had not insurance for a COVID-19 positive patient, then you do not need to file Medicaid if they received retroactive coverage. You just need to be able to prove under audit that when you filed you verified eligibility.





Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

May 27, 2020

Webinar Video Replay

Questions and Answers Transcript

The Governor put out Executive Order #2020-39. Our governor has issued an EO addressing EMS. She has lessened the staffing levels across the board. Will the insurance companies still reimburse with lower staffing levels that have been approved by our state? IE ALS = Paramedic + MFR is now allowed.


There is an Executive Order regarding licensing, which will be your best friend. It is a really good move for your Governor to put in an executive order relaxing their credentialing requirements that make up either an ALS or BLS call. As long as you have an EO relaxing it, still allowing it to still be an ALS, then MCR, MCD and Commercial Payers will reimburse you, unless you have very specific contracts that actually list exactly who it is that makes it one; most people follow local and state guidelines as it deals with credentialing, as long as your contract indicates that, the EO will be allowed for you to continue to bill as long as you are following within those parameters.




Any consideration of this on the Ambulance Cost Report?


Unfortunately, because we do not do ambulance cost reports right now, they are looking at the spend. This public health emergency will not be a factor in any funding that we would currently receive right now. If that did not answer your question, please follow up.




On the Accelerated/Advance payment, current claims will be paid and the recoupment will not take place until 120 days from the date the advance payment was made. Is this correct?


That is absolutely correct. Under this PHE it is usually 90 days, but they will give you 120 days from the date that you get paid before doing the recoupment. It is my understanding that they will work with you on a schedule; you will want to work on that with your MCR Administrative Contractor.




What if you are a for-profit entity but as a JV with a non-profit hospital?


If you are a for-profit entity, you should be working with that nonprofit hospital entity on how they are requesting public assistance from FEMA; you directly cannot directly go to FEMA, but you should be able to go through your hospital since you have a JV with the non-profit hospital.




Will there be any CARES funding for entities that have an affiliation with an entity with greater than 500 employees?


This is going to the PPP program and economic injury components of it. We are actively working on this as an industry to get the affiliation requirements modified to allow for the NAICS industry code to include ambulances in the over 500 employees. We are actively advocating this and have the ears of leadership on Congress, who understands the issue. As you probably heard from leadership, they want to put an additional 325 Billion to 350 Billion additional dollars into the Small Business Package. If we can get this nuance in there, it will take care of this question. I suggest you all reach out to your local delegation to help them understand that urgency.




Is there any talk of CMS covering A0382?


No. What we are asking for at this point in time, is from the regulatory side of it that they can possibly pay for COVID related claims at the ALS base rate. On the statutory side, we are asking for an economic stimulus package that we get a 20% add on payment for ALL Medicare transports happening through this PHE (not just COVID transports) retrospective to 3/1.




MOST of the ICD10 COVID codes are specific to COVID - most of our transports coming out of the hospital state "possible COVID" - test results aren't back yet - how do we use the ICD10 codes when we don't have a COVID diagnosis?


Your primary should be whatever condition they are complaining about and why you’re picking them up, your secondary code should be the Z code if they are possible COVID; there are payers rejecting them due to not being medically necessary if they don’t have the Z code. Get with them to create some clarification waivers. Your local lobbying can do a lot of good for you at this level. Humana, Cigna and Aetna have come out with specific guidance on how they will handle.




Has CMS made a decision on signatures for transport services?


In the last CMS waiver guidance, they gave direction on this, but did not include ambulance. In the next waiver, we should see clarification on this for ambulance. In the meantime, use a common sense approach. When CDC has issued guidance stating we need a 6ft distancing process, we obviously can’t get a signature with an iPad or electronic medical record. Use your due diligence and make note that this is a COVID (or presumptive) related transport/patient.




We are receiving multiple calls and requests from patients living at home who have lost their POV/Community w/c transportation to dialysis. Is there a way to transport them by ambulance and bill?


We are currently looking in to this. It will be based upon your region. Document, document document. Use common sense approach. You will need to be able to show that it was logical and necessary to provide this transport.




What if you are a not for profit ambulance service?


You will need to first reach out to your local Emergency Management Department, or appropriate State Emergency Management representative to apply for Public Assistance Funding.




Any word on if CMS will delay cost reporting for those agency's that have been chosen to report this year?


As of now, cost data collection has not been waived. As you can imagine, CMS is currently only processing waivers related to COVID-19 and since data collection is not required until 5 months following end of your fiscal year reporting period if you were selected in round 1, we do not expect anything on this in the near future. It should be noted that there is already the ability to request an exemption in reporting due to a hardship.




You mentioned 20% increase for COVID-19 related claims. Do you recommend a separate Claim charge or a global increase?


We are recommending a 20% add-on payment for all Medicare transports during the Public Health Emergency declaration. A typical add-on payment would be for the base rate and mileage for each claim. Note: the request is for all Medicare transports and not just COVID-19 related. We may have to negotiate to reimburse only COVID-19 related claims but the ask is for all Medicare claims at this time.




Has there been any direction regarding direct billing for treatment in place or Telehealth for EMS agencies?


At this time we are still working with CMS for a waiver on reimbursement for the response to a call and treating the patient in place. We are also working on legislation to be passed in Stimulus #4 that will allow for treatment in place in the event we are not successful with CMS. It appears CMS and the Office of General Counsel believe they do not have the statutory authority to allow for payment for the treat in place since Medicare payment policy is a transport benefit only for ambulance providers and suppliers. We disagree with their interpretation and are working with CMS leadership.




What is the turn around time under the Accelerated & Advanced Payments Program for MAC to process the payments?


It usually takes 2 - 3 weeks but they are turning around the requests within 5-7 days. You will want to apply through your MAC.




HHS Grant Program. $30BN released and 0.86% allocated to EMS totaling ~$258MM. Is this available to both public & private services? If so, how do we apply?


According to the press release, there is no application for this original $30B disbursement. It will be deposited directly. We are still waiting on the when and how. Stay tuned.




If you are a Private For Profit EMS Agency that provides 911 services for multiple Counties, would you have to go through each county individually on FEMA opportunities, and if so would you have to apply through the County Commission, or could you also qualify through the 911 center itself?


I would suggest you try and do a state contract through FEMA. If the state is unwilling to do a global contract, I would do the 80/20 principal and work with those locations that have the largest COVID-19 related expenses.





Virtual Town Hall w/Asbel Montes

Your Questions. Answered Live.

May 5, 2020

Webinar Video Replay

Questions and Answers Transcript

If the Ambulance Service is Out of Network and no benefits paid, can we submit through the COVID Claim CARE Act portal?


This is for individuals who are uninsured (not uncompensated care). The intent of the uninsured dollars that were appropriated here were for individuals that did not have any insurance at all. However, if it is COVID related, there are some tweaks in there regarding deductibles. Some of you indicated that in some areas some insurance carriers are not paying anything for out of network. There has been sufficient pressure from some insurance commissioners in some states that has put pressure on those networks that it doesn’t matter if it is in or out of network, they should cover as if it was in network. You should not put that in and attest that it is an uninsured patient because if you do, technically you are falsifying the attestation. I suggest you work with your local insurance commissioner through these schematics because it has been successfully overturned in other states.




If we bill insurance and the charges are denied as non-covered, can we submit through the COVID Claim CARE Act portal?


I am questioning the non-covered for a COVID related patient based upon these nuances where many of your large major health payers are actually covering these treatment services. If it was an early date of service (before February 4) I would suggest get with the health plan who denied as non-covered to reprocess the claim. You shouldn’t technically have non-covered under the conditions of how this uninsured COVID related portal is going to work. This portal is only for patients who do not have insurance. You need to have a separate process for COVID and non-COVID related in case there is a processing error.




Could you clarify the need/use for special modifiers such as CS and CR?


This question is looking for guidance around Medicare/other payers wanting to use the CR for all COVID related claims. The CS is a modifier that will waive copays and deductibles. The CR modifier should be on all Medicare claims for COVID presumptive and COVID related claims as a tracking mechanism for Medicare. The CS modifier is a waiver. I heard from two different Medicare Administrative Contractors (MAC) that they are waiving it. I should know by Thursday if the CS modifier is appropriate to waive those copays. I do understand that there are two MAC’s that are suggesting ambulance services use the CS modifier to waive the copay and deductible; I have not been able to confirm this yet, but should have confirmation by Thursday of this week and can follow up with you on that.




For public government agencies who are registering for COVID-19 uninsured patient portal we are getting stuck at the very beginning where it asks for the Medicare ID and the tax classification. Typically we select “other” and then identify ourselves as government or municipality, etc. It does not give us this option. What recommendation do you have on this as we cannot continue?


I have not heard feedback yet regarding this. I did get receive feedback that they are following up on this issue to figure out a work around. I hope to have an answer by this evening on how to navigate through this issue.




Is the portal only for confirmed COVID or can you also submit suspected?


I have not asked this question yet because it can be perceived in the instructions that it includes both. It can also be perceived that it only includes those that are confirmed by using the U code after 4/1 or the B code prior to 4/1 depending on how you are reading the instructions. As a general rule for what I am doing, I am going to be submitting both at this time through the uninsured portal as I do not want to ask at this time since it can be interpreted both ways.




Will the treated in place (aka Treated not transported) be eligible for billing to HRSA for non-insured patients?


At this time, no, as they are only paying for services that are currently covered under the Medicare fee for service program. If it is a non covered service, it will not be under the uninsured.




Can non-hospital based private ambulance services bill through the HRSA website?


Absolutely, you can! This is open to everyone. Direction on governmentals should be available later this evening. If you haven’t registered, I suggest you do so today, as it is at least a two day process for you to be authenticated.




What is the timeframe from application to receipt of Tranche 2 provider relief funds?


Once your application is approved, they will distribute the funds every Friday as they receive/approve applications. It is anticipated and expected that many who applied should start to see the funding this Friday and every subsequent Friday until all approved applications are funded.




How specific do the patients’ complaints need to be to be considered a suspected COVID patient?


There has been CDC guidance that was given on how the questions to ask a patient to determine if they are a suspected COVID patient. I am assuming you are not using this guidance.




If you accept the first and second round of funding, how long do we have to not balance bill presumptive or positive COVID patients?


Most of the emergency rules/guidance is throughout the public health emergency. Once the PHE has been rescinded by the President of the United States, that is typically when everything ceases on the requirements from some of these waivers.




Insurance companies are still applying co-pays and deductibles when you use the Z correlated diagnosis Codes when you suspect somebody has COVID. Please advise.


I am assuming that an insurance company has indicated to you that they are waiving copays and deductibles for suspected COVID patients. The first thing you need to do is, did you follow the requirements as outlined by the health plan? If you did, then you need to engage the health plan. If you did not, then you need to correct your billing practices to do that. The second thing is, if you had followed those guidelines, you need to determine if ambulance service is included. I know just because there was guidance given by many of the health plans, I followed up with every single one of them to ensure that ambulance services were included in that guidance. I am suggesting to you to not take it they are intentionally excluding you; if you call them, they may have not realized they didn’t include you in it and need to modify.




The HHS portal for the uninsured (apparently linked with Optum Pay/United HealthCare) seems to be lagging (unless I did it wrong). I registered last week and I am getting various emails one time it states in process, then it states our ACH has been processed, then it later states it’s been changed back, etc. I called, they tell me it takes 7-14 days to finalize the process and it shows I am ok. Has this been the norm?


You are the first to report this to me. I am going to note this; if anyone else on the line has this concern as well, please email us so we can track it and follow up/report this issue.




When reporting Tranche 2, I understand there are many ways to look at the data but wanted to confirm they are only asking that you estimate your revenue loss for March and April only (not a full year of expected loss).


You are correct. They are only looking at March and April and it is an estimate. Remember that in an estimate you need to be able to justify. For some people who have relatively little growth year after year, it might be appropriate to compare where you were in March/April of last year to March/April of this year. Utilize a comparative pre-COVID quarter/month/year to what you would have anticipated had COVID had not happened to estimate that loss down to the March/April. Under an audit, you need to be able to prove your estimate.




We asked HRSA and were told that governmental entities should check the S core box and then check the state local government box below. Are you hearing this?


I have not heard this; if this is what they are telling you, this may be the solution but I haven’t been able to confirm yet. I hope to have an answer by this evening.




Would paying hazard pay bonuses to employees be a forgivable expense under the PPP?


Under the PPP, it is any cash, wages or money that is paid to an employee may be used for the purposes of the PPP funds. My suggestion is to make sure you document of any hazard pay/differential. Make sure you utilize the Department of Labor and Labor Standards Act weighted average overtime calculation should those individuals have hazard pay where they might have different rates of pay.




Does the HHS funding have an Expiration date to it as to when we are no longer required to accept the terms?


Typically, the terms and conditions would go through the PHE cycle.




Does the revenue loss estimate only apply to ambulance, or is this a general requirement for all providers including hospitals?


This number applies for any applicant for the 2nd tranche funding request for all healthcare providers and suppliers that do not do cost reporting. I am unsure what the “verification” process is for those providers that do cost reports.




The Terms and Conditions of the uninsured lead us to believe it's only for the Positive patients. Would this trump the instructions?


The T&C is unclear. I agree it “leads you to believe it is only for Positive patients”; however, it is not clear and there is an argument for ambulance services who do not diagnose patients that presumptive could be included. My suggestion is to submit uninsured claims for reimbursement that are presumptive and positive for reimbursement.




Please share the link to the sample form of the uninsured COVID-19 claims.


https://coviduninsuredclaim.linkhealth.com/claims-and-reimbursement.html





Virtual Town Hall w/Asbel Montes

Cutting Through the Noise

April 22, 2020

Webinar Video Replay

Questions and Answers Transcript

Has there been any further clarification about billing the HRSA Covid-19 Uninsured program for presumptive patients?


It was always under the assumption that presumptive and positive we're going to be paid. But unfortunately, that terms and conditions that you sign is for positive patients.

It has not been clarified right now. Currently, It is for positive only. There are additional avenues available for reimbursement for uninsured patients but that would be an effort at the state and local level.




Aside from HHS or PPP what other forms of relief should we be looking into?


There are 3 buckets of funding available: Payroll Protection Program, CARES Act Funding and FEMA. The CARES Act funding has a few avenues available: (1) distributions through Health & Human Services (HHS), as well as distributions through the Coronavirus Relief Fund (CRF). The CRF funds are distributed directly to state and local governments by the U.S. Treasury. These funds are available for loss revenue and increased expenses related to the Public Health Emergency. You will need to work with your state government and/or local jurisdictions to get access to these funds.




How long do we have to submit bills for uninsured COVID?


Until they run out of money and the public health emergency is over. We haven't been notified yet that they ran out of money... I would keep submitting your claims until they tell you there's no more money left available.




If we were denied for the second wave of HHS funding, can we still apply for the third wave?


I'm assuming when you mean denial that the formulary had you as a negative, so that's not really a denial. If that is what you are referencing, it just means that you did not qualify for a second level because the formula funding saw that you had already received a substantial amount of money based upon the formulary that was put together (i.e. 2% of that net operating revenue number based upon your tax filings or your balance sheet and that you uploaded your audited financials). Technically, yes, you would apply. From what I understand, it's going to be another application process.




Is there an update regarding HHS uninsured funding applying to only uninsured?  I wonder about the time period for submitting those claims and receiving dedicated funds.  Areas of the country are currently seeing spikes.


Right now, the uninsured funding is only available to those uninsured. When you read the terms and condition, you have to verify that they have no other insurance source. And, according also to Terms and Conditions you signed, it's only available to positive COVID patients. As of right now, there is no end date on that. Basically, as long as there's funds available, they are going to reimburse for the uninsured COVI-19 positive patients.




Is there any stimulus money for additional cost that we have incurred due to Covid-19?  If so, how do we apply for them?


In the next allocation, you'll see the application process open up. We're not really sure yet what the formulary is. We do understand that it is going to be looking at increased expenses aound the PPE area. Also an update to your lost revenue numbers, because you only recorded March and April and we're now into June.




Since we provided March/April lost revenue re the CARES Act, does this mean we are prohibited from claiming lost revenue from other government reimbursement sources? If so, can we seek lost revenue for other months from the Feds?


You need to have a formalized documentation system that is keeping track of all funding received due to the Public Health Emergency. This could be funding received from the Paycheck Protection Program, FEMA, HHS and any funds received from state or local government related to the PHE. Once the PHE is rescinded, you will then need to compare your lost revenue and increased expenses throughout the PHE to the revenue you received from all sources. If you have received more revenue, you will need to reimburse the federal government. If you have receive less revenue from federal sources compared to your lost revenue and increased expenses, then you will not be required to refund the federal government. Documentation will be key! Document, document, document!




When are the first CARES Act quarterly reports due?  Are there any published report specifications and requirements?


Currently, the only requirement is to submit your financial statements via the attached portal. If you have already done this through Tranche 2 funding, then nothing is due at this time. If you did not complete the application for Tranche 2 funding, you will need to follow the instructions as indicated.

https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/for-providers/index.html




When will be get notified if we will receive money under Tranche 2 of HHS?


You should have been notified already. If not, please call (866) 569-3522.




Will any part of the funding provided to state and local governments under the US Treasury Coronavirus Relief Fund (i.e. the $1.25 billion minimum to each state) eventually be allowed for revenue replacement?


Currently, the CARES Act direction is specific on what state and local governments can use these funds for.

The guidance clarifies what costs are permissible under the CRF, noting that necessary expenditures incurred due to the public health emergency:

  • Must be used for actions taken to respond directly to the COVID-19 public health emergency
  • May include expenditures incurred to address medical or public health needs, as well as to respond to second-order effects of the emergency, such as providing economic support to those suffering from employment or business interruptions
  • Can’t be used to fill shortfalls in government revenue to cover expenditures that wouldn’t otherwise qualify under the statute

Only certain costs not accounted for in the government’s budget most recently approved as of March 27, 2020 are permitted. Costs will, however, meet the above requirement if the cost:

  • Can’t lawfully be funded using a line item, allotment, or allocation with that budget
  • Is for a substantially different use from any expected use of funds in such a line item, allotment, or allocation

A cost isn’t considered to have been accounted for in a budget merely because it could be paid from a budgetary stabilization fund, rainy day fund, or similar reserve account.




Will the Medicare sequestration roll back be permanent or will the 2% be back?


The Medicare sequestration roll back is temporary only and expires on 12/30/2020. It remains to be seen if Congress will make this permanent or not.




Will the Round Two Cares Act Application Portal open up again? We didn't have enough time to complete the application and want additional funding.


Round Two closed on 6/3/2020. HHS will be doing a Round 3 funding soon.




Any updates on auditing or reporting - can we just claim a revenue loss based on call volume or do we also have to show what the money was spent on?


Based upon the FAQ posted on 6/13/2020 via https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/faqs/index.html. See the following:

Recipients of Provider Relief Fund payments do not need to submit a separate quarterly report to HHS or the Pandemic Response Accountability Committee. HHS will develop a report containing all information necessary for recipients of Provider Relief Fund payments to comply with this provision. For all providers who attest to receiving a Provider Relief Fund payment and agree to the Terms and Conditions (or retain such a payment for more than 90 days), HHS is posting the names of payment recipients and their payment amounts on its public website Tracking Accountability in Government Grants System (TAGGS). HHS is also working with the Department of Treasury to reflect the aggregate total of each recipient's attested to Provider Relief Fund payments on USAspending.gov. Posting these data meets the reporting requirements of the CARES Act. See Appendix A of OMB Memo M-20-21 - PDF [Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19)].

However, the Terms and Conditions for all Provider Relief Fund payments also require recipients to submit any reports requested by the Secretary that are necessary to allow HHS to ensure compliance with payment Terms and Conditions. HHS will be requiring recipients to submit future reports relating to the recipient's use of its PRF money. HHS will notify recipients of the content and due date(s) of such reports in the coming weeks.




We have never had to submit Cost Data for Novitas, but understand it is a requirement due to the HHS funding. What format do we submit it in and where?


Please see answer above.




Traunch 3 includes all providers, including hospitals?


They're indicating it is a general allocation. And if it's a general allocation, then it would include everybody. Do not hold me to that. Remember, this is what they were thinking. They could make it a little bit more specific because the hospitals have been receiving a ton of money. And many of you have been probably talking to some of your hospital colleagues and some of them are actually sending money back because they've got way too much that they can't justify, especially in areas that may not have been hotspots that right now, if it is a general allocation, it would include all suppliers and providers of health care.




Could you please talk about the application due July 20th for the upcoming $15B HHS allocation for agencies participating in Medicaid and CHIP?


If you received funding in Round 1 or Round 2, you will not be eligible for the Medicaid and CHIP funding.




Are there any tax implications for the CARES ACT funds?


I'm going to tell you to get with your tax advisor on that. That is not my area of specialty. And there are depending upon how you have set yourself up. But I would definitely get with your tax advisor on that.




We teach EMT classes. Do these lost revenues count?


Anything related to the provision of healthcare that's related to the corona virus and pandemic would qualify. If you teach EMT classes and that was a source of revenue and because of the pandemic, you've seen a loss of EMT. And so you've seen a loss of revenue related to that. That would be a justifiable revenue loss.




If a patient becomes retroactive with Medicaid and we already received payment from the Uninsured Program - how do we go about contacting HRSA for refunds?


If at the time you validated and checked for insurance, and the patient had not insurance for a COVID-19 positive patient, then you do not need to file Medicaid if they received retroactive coverage. You just need to be able to prove under audit that when you filed you verified eligibility.





Navigating Reimbursement During the Next 90 Days of COVID-19 w/ Asbel Montes

April 8, 2020

Webinar Video Replay

Questions and Answers Transcript

The Governor put out Executive Order #2020-39. Our governor has issued an EO addressing EMS. She has lessened the staffing levels across the board. Will the insurance companies still reimburse with lower staffing levels that have been approved by our state? IE ALS = Paramedic + MFR is now allowed.


There is an Executive Order regarding licensing, which will be your best friend. It is a really good move for your Governor to put in an executive order relaxing their credentialing requirements that make up either an ALS or BLS call. As long as you have an EO relaxing it, still allowing it to still be an ALS, then MCR, MCD and Commercial Payers will reimburse you, unless you have very specific contracts that actually list exactly who it is that makes it one; most people follow local and state guidelines as it deals with credentialing, as long as your contract indicates that, the EO will be allowed for you to continue to bill as long as you are following within those parameters.




Any consideration of this on the Ambulance Cost Report?


Unfortunately, because we do not do ambulance cost reports right now, they are looking at the spend. This public health emergency will not be a factor in any funding that we would currently receive right now. If that did not answer your question, please follow up.




On the Accelerated/Advance payment, current claims will be paid and the recoupment will not take place until 120 days from the date the advance payment was made. Is this correct?


That is absolutely correct. Under this PHE it is usually 90 days, but they will give you 120 days from the date that you get paid before doing the recoupment. It is my understanding that they will work with you on a schedule; you will want to work on that with your MCR Administrative Contractor.




What if you are a for-profit entity but as a JV with a non-profit hospital?


If you are a for-profit entity, you should be working with that nonprofit hospital entity on how they are requesting public assistance from FEMA; you directly cannot directly go to FEMA, but you should be able to go through your hospital since you have a JV with the non-profit hospital.




Will there be any CARES funding for entities that have an affiliation with an entity with greater than 500 employees?


This is going to the PPP program and economic injury components of it. We are actively working on this as an industry to get the affiliation requirements modified to allow for the NAICS industry code to include ambulances in the over 500 employees. We are actively advocating this and have the ears of leadership on Congress, who understands the issue. As you probably heard from leadership, they want to put an additional 325 Billion to 350 Billion additional dollars into the Small Business Package. If we can get this nuance in there, it will take care of this question. I suggest you all reach out to your local delegation to help them understand that urgency.




Is there any talk of CMS covering A0382?


No. What we are asking for at this point in time, is from the regulatory side of it that they can possibly pay for COVID related claims at the ALS base rate. On the statutory side, we are asking for an economic stimulus package that we get a 20% add on payment for ALL Medicare transports happening through this PHE (not just COVID transports) retrospective to 3/1.




MOST of the ICD10 COVID codes are specific to COVID - most of our transports coming out of the hospital state "possible COVID" - test results aren't back yet - how do we use the ICD10 codes when we don't have a COVID diagnosis?


Your primary should be whatever condition they are complaining about and why you’re picking them up, your secondary code should be the Z code if they are possible COVID; there are payers rejecting them due to not being medically necessary if they don’t have the Z code. Get with them to create some clarification waivers. Your local lobbying can do a lot of good for you at this level. Humana, Cigna and Aetna have come out with specific guidance on how they will handle.




Has CMS made a decision on signatures for transport services?


In the last CMS waiver guidance, they gave direction on this, but did not include ambulance. In the next waiver, we should see clarification on this for ambulance. In the meantime, use a common sense approach. When CDC has issued guidance stating we need a 6ft distancing process, we obviously can’t get a signature with an iPad or electronic medical record. Use your due diligence and make note that this is a COVID (or presumptive) related transport/patient.




We are receiving multiple calls and requests from patients living at home who have lost their POV/Community w/c transportation to dialysis. Is there a way to transport them by ambulance and bill?


We are currently looking in to this. It will be based upon your region. Document, document document. Use common sense approach. You will need to be able to show that it was logical and necessary to provide this transport.




What if you are a not for profit ambulance service?


You will need to first reach out to your local Emergency Management Department, or appropriate State Emergency Management representative to apply for Public Assistance Funding.




Any word on if CMS will delay cost reporting for those agency's that have been chosen to report this year?


As of now, cost data collection has not been waived. As you can imagine, CMS is currently only processing waivers related to COVID-19 and since data collection is not required until 5 months following end of your fiscal year reporting period if you were selected in round 1, we do not expect anything on this in the near future. It should be noted that there is already the ability to request an exemption in reporting due to a hardship.




You mentioned 20% increase for COVID-19 related claims. Do you recommend a separate Claim charge or a global increase?


We are recommending a 20% add-on payment for all Medicare transports during the Public Health Emergency declaration. A typical add-on payment would be for the base rate and mileage for each claim. Note: the request is for all Medicare transports and not just COVID-19 related. We may have to negotiate to reimburse only COVID-19 related claims but the ask is for all Medicare claims at this time.




Has there been any direction regarding direct billing for treatment in place or Telehealth for EMS agencies?


At this time we are still working with CMS for a waiver on reimbursement for the response to a call and treating the patient in place. We are also working on legislation to be passed in Stimulus #4 that will allow for treatment in place in the event we are not successful with CMS. It appears CMS and the Office of General Counsel believe they do not have the statutory authority to allow for payment for the treat in place since Medicare payment policy is a transport benefit only for ambulance providers and suppliers. We disagree with their interpretation and are working with CMS leadership.




What is the turn around time under the Accelerated & Advanced Payments Program for MAC to process the payments?


It usually takes 2 - 3 weeks but they are turning around the requests within 5-7 days. You will want to apply through your MAC.




HHS Grant Program. $30BN released and 0.86% allocated to EMS totaling ~$258MM. Is this available to both public & private services? If so, how do we apply?


According to the press release, there is no application for this original $30B disbursement. It will be deposited directly. We are still waiting on the when and how. Stay tuned.




If you are a Private For Profit EMS Agency that provides 911 services for multiple Counties, would you have to go through each county individually on FEMA opportunities, and if so would you have to apply through the County Commission, or could you also qualify through the 911 center itself?


I would suggest you try and do a state contract through FEMA. If the state is unwilling to do a global contract, I would do the 80/20 principal and work with those locations that have the largest COVID-19 related expenses.





 
 
 
 
 
 
 
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