HHS stated it will soon provide appropriate contact information for those wishing to take this action. It is important to note that as a condition of receiving these funds, providers must agree not to seek collection of out-of-pocket payments from a COVID patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
HHS stated that it is working to make additional distributions from the fund to target certain providers. Breadcrumb Home Advocacy Special Bulletin. Priorities for Remaining Funds HHS stated that it is working to make additional distributions from the fund to target certain providers. Other Resources. The goal for this opportunity was to reach the remaining providers participating in state Medicaid and CHIP programs that did not receive funding in the Phase 1, Medicare General Distribution, as well as certain dental providers.
Since the announcement, HHS has posted resources and hosted a number of webinars targeted at providers and provider organizations to answer questions and assist eligible providers with the application process. The initial deadline of July 20, , was extended to August 3, , based on provider feedback that they learned about the program too close to the deadline and needed more time to complete their application. HHS continues to keep an open line of communication with provider organizations, congressional, state and local leaders, in a collective effort to get the word out about this program, and HHS has learned that a second extension would be beneficial to those providers.
By giving providers until August 28, to apply, HHS is hopeful it has struck the right balance in terms of providing as much flexibility as possible, recognizing the constraints on smaller practices already operating on thin margins with limited administrative staff.
HHS will also soon be providing a more simplified application form in response to ongoing dialogue focused on improving the provider experience.
Providers that do not submit comprehensive cost reports with CMS were asked to submit revenue information to a portal to receive the balance of their 2 percent payment of General Distribution funds. The interim payment methodology must describe how states will compute interim payment amounts for providers e. CMS has said that it will consider such requests on an expedited basis. Retainer Payments. States can request authority to make retainer payments to certain habilitation and personal care providers to maintain capacity during the emergency.
Unlike interim payments, which are made before services are provided and subsequently reconciled so that providers are paid only for services actually rendered, retainer payments allow providers to continue to bill and be paid for certain services that are authorized in person-centered service plans to enable providers to maintain capacity when circumstances prevent enrollees from actually receiving those services.
For example, during the current pandemic, enrollees may not be able to receive in-person services due to self-quarantine rules. Such retainer payments are limited to personal care or attendant service providers while the enrollee is hospitalized or absent from their home. CMS has permitted states to make retainer payments since , in Olmstead guidance , to equalize treatment of personal assistance services and nursing facility services, for which bed hold payments are permitted. In the Olmstead decision, the U.
Supreme Court found that states have community integration obligations under the Americans with Disabilities Act. The National Association of Medicaid Directors has requested additional flexibility from CMS to enable states to make retainer payments to a broader set of providers using Section waiver authority. States can direct that managed care plans make payments to their network providers using methodologies approved by CMS to further state goals and priorities, including COVID response.
This strategy can address the scenario in which states are making capitation payments to plans, but providers are not receiving reimbursement from plans due to decreased service utilization while social distancing measures are in place and non-urgent services are suspended.
For example, states could require plans to adopt a uniform temporary increase in per-service provider payment amounts for services covered under the managed care contract, or states could combine different state directed payments to temporarily increase provider payments, according to recent CMS guidance. CMS explains that state directed increased payments for actual utilization of services can preserve the availability of covered services for enrollees during a time when providers may be experiencing dramatic utilization declines or incurring additional costs due to the public health emergency.
The guidance also says that states may use directed payments to address increased use of telehealth or other approaches to maintain access to care for all enrollees or specific subgroups with specialized needs during the emergency. States can direct payments to a class of providers, such as dental, behavioral health, home health and personal care, pediatric, federally-qualified health centers, or safety-net hospitals, to support providers that may serve a high proportion of Medicaid enrollees and may be disproportionately affected by the public health emergency.
Directed payments must be appropriate and reasonable compared to the total payments the provider would have received in the absence of the public health emergency. Section Waiver Disaster Relief Funds. In prior emergencies, states have used Section waivers to create disaster relief funds to support Medicaid providers experiencing high levels of uncompensated care or fiscal instability.
For example, disaster waivers approved in response to Hurricane Katrina included uncompensated care funds for affected states. During state stakeholder calls , CMS has said it will consider other available federal funds before approving state requests for Section authority for certain activities. However, the amount and allocation of those funds is still a question. States can also make changes through traditional SPAs though no state to date has changed provider payment policies in response to COVID using a traditional SPA and can implement other changes under existing administrative authority that do not require SPA approval.
The section below highlights the most common actions that states are taking regarding provider payment under these authorities Figure 1. The most common policy adopted by states to support providers across service type and authority is increasing payment rates.
As of June 11, , twenty-five states have taken action to increase provider payment rates for state plan services through Disaster-Relief SPA or other administrative authority, 29 states have done so for HCBS waiver services using Appendix K, and one state is using a Section waiver to increase rates for HCBS.
States adopting temporary provider payment rate increases for state plan services using Disaster-Relief SPA or other administrative authority are most frequently targeting nursing facility services. Some states limit the additional payments to nursing facilities or patients with a COVID diagnosis, while others apply them to all nursing facilities to account for increased costs related to staffing, equipment and cleaning as a result of the emergency.
Alabama also is providing an additional add-on cleaning fee. Arkansas adopted temporary supplemental payments that increase weekly pay of direct care workers in nursing facilities, intermediate care facilities, and psychiatric treatment centers; the payments include a base supplemental payment according to number of hours worked and an additional tiered acuity payment for those working in facilities with COVID positive patients.
A couple of states have adopted temporary payment rate increases that apply to a range of providers. In March, Arizona passed legislation to increase payment rates for Medicaid physicians and dental providers, funded through a hospital assessment.
Among the 29 states using Appendix K to temporarily increase provider payment rates for HCBS waiver services, the types of services commonly targeted for increases are residential habilitation, home health, respite, personal care, and nursing.
Michigan is adding a supplemental payment for providers of personal care and behavioral health treatment technician in-person services. Many states are adopting retainer payments for HCBS the only services for which they are available. Thirty-seven states have established retainer payments through Appendix K to support HCBS waiver service providers and address emergency-related issues.
Two states WA and NH have an approved Section waiver that authorizes retainer payments for personal care and habilitation services provided under state plan authority. Vermont is only state providing temporary retainer payments to a broader set of Medicaid providers through existing authority to set provider payments under its Section waver. Vermont has a unique managed care-like delivery system in which the state Medicaid agency contracts with another state entity that operates as a non-risk prepaid health inpatient plan.
Few states are using interim or advance payments to support providers.
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