Tag: Medical Group Management Association (MGMA)
REPAYMENT OF ADVANCE PAYMENTS
QUESTION: We have received letters indicating when repayment of Advanced Payments will begin. Has Medicare released anything on exactly how that will work and how the remit will look? Will there be specific CARC or RARC codes used? Thanks!
MGMA REPLY:
Thanks for posting this question! Earlier this month, CMS announced the details of Medicare Accelerated & Advance Payment (AAP) recoupment, which are consistent with legislation passed by Congress in September:
“Providers were required to make payments starting in August of this year, but with this action, repayment will be delayed until one year after payment was issued. After that first year, Medicare will automatically recoup 25 percent of Medicare payments otherwise owed to the provider or supplier for eleven months. At the end of the eleven-month period, recoupment will increase to 50 percent for another six months. If the provider or supplier is unable to repay the total amount of the AAP during this time-period (a total of 29 months), CMS will issue letters requiring repayment of any outstanding balance, subject to an interest rate of four percent.”
Regarding remits, CMS indicates in its AAP FAQ, “Providers and suppliers will see the offset amount reflected on their Remittance Advice. Providers and suppliers should contact their MAC to receive current balance and payment information related to the repayment of their AAP payment.” I have not yet seen specifics around which codes will be used on the remits. However, the Agency plans to issue further information on the recoupment process at a later date, and the details of these adjustment codes may be covered in future guidance.
Please let me know if I can provide any further clarification!
Best,
——————————
Matt Devino
Associate Director, Government Affairs MGMA
Washington DC
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ADA Compliance & Translation Services
On 10/14/2020, This question was posed to MGMA regarding Translation Services.
I’m aware of the requirement to provide translation services for patients in compliance with ADA Title III, but I would like to know definitively whether translation apps such as Google Translate can meet the requirement in some scenarios, or if we must continue to use certified healthcare interpreters. Can anyone point me in the right direction for either written guidance or an official opinion on this?
Matt Devino, Associate Director, Government Affairs MGMA, Washington DC, responds.
Thanks for posting this question. For people who are deaf or have a hearing disability, federal law requires providing a “qualified” interpreter. For the written guidance, please take a look at the Americans with Disabilities Act regulations at 28 CFR 36.303; 36.104 and Section 1557 regulations at 45 CFR 92.102. These regulations do not require that interpretation services be certified; instead, the legal standard is intended to be more flexible. While this offers greater latitude for group practices to select appropriate services, what “qualified” actually entails may be hazy in some cases.
Applicable regulations state that qualified “means an interpreter who, via a video remote interpreting (VRI) service or an on-site appearance, is able to interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.” Remote interpretation services are permitted, including “videotext displays,” so long as they are qualified. See 45 CFR 92.102(a)(1)(i) and this ADA guidance for more information. There is no exhaustive list of what types of interpretation services meet this standard, which can make applying it difficult in practice.
A follow up question was posed on 10/15/2020
Thank you both for your inputs and references as well as the clarification that the ADA requirements are for the deaf or those with hearing disabilities.
Your responses, however, makes me wonder about another requirement, if in fact it is one, for those who do not speak English. Not speaking nor understanding English is obviously not a disability, but everyone I have consulted tells me we are “required” to provide translators for those who don’t speak English and I’m now wondering if it’s a requirement or a courtesy? And if it’s a requirement, I would love to know the references for these too if you know them…or if someone else does. Is it perhaps a requirement by CMS or our other payers? Either way, thank you for your initial response and I would sincerely like to learn more about what options are available to deal with non-English speaking patients too. Are these candidates for Google Translate or some other widely used app…?
Matt Devino, Associate Director, Government Affairs MGMA, Washington DC, again responds.
Thanks for posting this question. For people who are deaf or have a hearing disability, federal law requires providing a “qualified” interpreter. For the written guidance, please take a look at the Americans with Disabilities Act regulations at 28 CFR 36.303; 36.104 and Section 1557 regulations at 45 CFR 92.102. These regulations do not require that interpretation services be certified; instead, the legal standard is intended to be more flexible. While this offers greater latitude for group practices to select appropriate services, what “qualified” actually entails may be hazy in some cases.
Applicable regulations state that qualified “means an interpreter who, via a video remote interpreting (VRI) service or an on-site appearance, is able to interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.” Remote interpretation services are permitted, including “videotext displays,” so long as they are qualified. See 45 CFR 92.102(a)(1)(i) and this ADA guidance for more information. There is no exhaustive list of what types of interpretation services meet this standard, which can make applying it difficult in practice.
Medicare Accelerated and Advance Payment Program (APP)
From: Drew Voytal
Associate Director
MGMA Government Affairs
Washington, DC
President Trump signed a continuing resolution appropriations bill into law that funds the federal government through December 11, 2020; section 2501 also includes several improvements to the Medicare Accelerated and Advance Payment Program (APP), including relaxing repayment terms. Upon request of a hospital or group practice that received accelerated or advance payments under Medicare Part A or Part B, CMS can:
- Delay recoupment of payments until one year from the issuance of the advanced payments;
- Once recoupment begins, apply a graduated recoupment schedule, where 25% of Medicare payments would be withheld during the first 11 months of recoupment, and 50% of Medicare payments would be withheld during the following six months; and
- Extend the period during which recipients must fully repay the advance payment amount in full to 29 months from the date of the first payment.
- The bill also lowers the interest rate on outstanding balances remaining after the 29-month repayment period from 10.25% to 4%.
CMS has not yet published information for groups wishing to avail themselves of these benefits, but we anticipate the agency will provide further information on how to make such a request. We will notify members once we see something.
Public Health Emergency Extended
HHS Secretary Alex Azar has officially renewed the COVID-19 public health emergency, resulting in a continuation of the telehealth waivers and other flexibilities that have allowed medical groups to care for patients during the pandemic. The renewed PHE determination is effective Friday, Oct. 23, and will terminate 90 days later on Thursday, Jan. 21.
Announcement from: Matt Devino
Associate Director, Government Affairs MGMA
Washington DC
New Funding for the Provider Relief Fund
From MGMA
Today, HHS has announced that applications will be accepted beginning on Monday, Oct. 5 for $20 billion in new funding under Phase 3 of the PRF General Distribution allocation. Under this new phase, providers that have already received Provider Relief Fund payments will be invited to apply for additional funding that considers financial losses and changes in operating expenses caused by the coronavirus. Previously ineligible providers, such as those who began practicing in 2020 will also be invited to apply, and an expanded group of behavioral health providers will also be eligible for relief payments.
Deadline: Providers will have from Monday Oct. 5 through Nov. 6 to apply, however HHS is encouraging early application to “expedite [its] review process and payment calculations.”
Eligibility
- Providers who previously received, rejected or accepted a General Distribution Provider Relief Fund payment. Providers that have already received payments of approximately 2% of annual revenue from patient care may submit more information to become eligible for an additional payment.
- Importantly, even if you already received payments of approximately 2% of annual revenue from patient care, you may submit more information to become eligible for an additional payment.
- Behavioral Health providers, including those that previously received funding and new providers.
- Healthcare providers that began practicing January 1, 2020 through March 31, 2020. This includes Medicare, Medicaid, CHIP, dentists, assisted living facilities and behavioral health providers.
Payment Methodology
- All provider submissions will be reviewed to confirm they have received a Provider Relief Fund payment equal to approximately 2 percent of patient care revenue from prior general distributions. Applicants that have not yet received Relief Fund payments of 2 percent of patient revenue will receive a payment that, when combined with prior payments (if any), equals 2 percent of patient care revenue.
- With the remaining balance of the $20 billion budget, HRSA will then calculate an equitable add-on payment that considers the following:
- 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
- Payments already received through prior Provider Relief Fund distributions.
We (MGMA) expect to see more information released by HHS over the coming days which we expect will be posted to the Provider Relief Fund website. We will communicate those details to members as they are made available.
Texas MGMA Virtual Conference – Not a Member? Not a problem!
The Texas Chapter of MGMA has announced it’s annual meeting will be virtual. The price for Members and Non- Members ($99) are the same.
The 2020 Annual Meeting is going Digital!
September 8-11, 2020
As a precaution and in consideration for the safety of our members and vendors the TMGMA Board has decided to hold a virtual meeting this year.
Topics Include:
- Best Practices for Medical Group Managers & the Pandemic
- Active Shooter Training: Stop the Bleed
- Cybersecurity Panel
- How to Avoid Burnout
- Commercial Payor re: Denials/Appeals Process for Prior Authorization and/or Contract Negotiations for In Network
- Medicare/Medicaid: Coding Updates for 2020
- Prior Authorizations in Texas: Burdens and Policy
- Status of Rural Health
- TMGMA Annual Business Meeting
- Principal Care Management
- MGMA Legislative UpdateTexas Bills: Prior Authorization, Claim Denials, Sales Tax Bills, Surprise Billing
Registration Information
Before August 15, 2020
*ALL PRICING BELOW WILL INCREASE $100 AFTER 08/15/20
Members
Active – $99
Affiliate – $99
Faculty – $99
Student – $99
Non-Members
Non-Member – $99
Affiliate Non-Member – $99
The Updated Skinny on Texas’ Surprise Billing Law, MGMA
by Joey Berlin, July 17, 2020
The Texas Medical Association has updated its white paper on Texas’ law for settling out-of-network billing disputes involving state-regulated health plans.
The eight-page white paper, first released last December, covers the ins and outs of Senate Bill 1264, the 2019 legislation now in effect. SB 1264 took patients out of the middle of surprise-billing disputes between certain out-of-network physicians and state-regulated health plans, allowing them to settle those disputes through an arbitration process similar to the one used to settle salary disputes in Major League Baseball.
The white paper update comes after the Texas Department of Insurance adopted a final rule touching on exceptions to SB 1264’s general ban on balance billing for out-of-network services the law covers. SB 1264 prohibits balance billing except in certain circumstances, which include required notice and disclosure.
The newly amended rules include these changes that TMA requested:
- Legal representatives or guardians of a patient may be the people to agree to an out-of-network physician’s required notice and disclosure of a potential balance bill;
- A physician may delegate the record-keeping of that notice and disclosure statement by allowing a practitioner’s “agent or assignee” to maintain a copy of the statement. Also, the statement only has to be maintained if the practitioner provides the medical service or supply at issue and sends a balance bill.
You can read the complete adopted rule on page 4,204 of the June 19 Texas Register.
To view the TMA updated white paper on Ink, follow this link.
A General Overview of SB 1264 and Texas’ New Arbitration Process for Certain Out-of-Network Claims June 30, 2020
[embeddoc url=”https://community.poetllc.org/wp-content/uploads/2020/07/Overview-of-SB-1264-TMA-06302020.pdf” download=”all” viewer=”google”]
The Rising Trend of Non-Physician Provider (NPP) Utiliaztion in Healthcare, 12/2016
[embeddoc url=”https://community.poetllc.org/wp-content/uploads/2020/06/The-Rising-Trend-of-Nonphysician-Provider-Utilization-in-Healthcare.pdf” download=”all” viewer=”google”]
MGMA Speaks on Telephone Visits 05132020
[embeddoc url=”https://community.poetllc.org/wp-content/uploads/2020/05/MGMA-On-Telephone-Only-Visits-05132020.pdf” download=”all” viewer=”google”]
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