MACs Announce Medicare Cost Report Delays; CMS Extends Deadlines
Breaking News: Congress passed and the President quickly signed into law on March 27 the CARES Act. This third COVID-19 relief package is estimated at two trillion dollars. There are many financial and tax policies to assist businesses and individuals. Watch CLA’s CARES Act Livestream on March 31 for details. Read CLA’s CARES Act summary and watch our blog for future health care insights. Be safe.
Recognizing the complexity and efforts that are and will continue to be involved with handling the COVID-19 outbreak, the Centers for Medicare & Medicare Services (CMS) and its intermediaries have extended a variety of deadlines and provided other flexibilities related to various programs and filing requirements.
Medicare Cost Reports
There are questions on whether CMS has or will extend cost reporting filing deadlines. While we have not seen a national announcement from CMS on this, we do know there are multiple Medicare Administrative Contractors (MACs) with approved filing deadline extensions.
As of March 27, we are aware of delays granted by WPS, Palmetto, NGS and Novitas. These are blanket extensions for these jurisdictions.
The filing extension for the following cost reports is now June 30, 2020:
- Fiscal Year End October 31, 2019 originally due by March 31, 2020
- Fiscal Year End November 30, 2019 originally due by April 30, 2020
The filing deadline for FYE December 31, 2019 is now July 31, 2020.
CLA Insight: Now might be a great time for providers to consider e-filing of cost reports. This was first made available by CMS last year. It is not mandatory yet, but e-filing makes sure the reports are submitted directly to CMS and processed more quickly. Any questions on how to e-file cost reports may be directed to Deb Freeland or your CLA advisor.
Regulatory Relief from Various Medicare Deadlines, Timelines
As the COVID-19 situation continues, CMS is providing a variety of measures to delay reporting or other requirements that will unduly burden providers during this time. Those include the following delays for physicians/clinicians, hospitals and post-acute providers.
Specific to Skilled Nursing Facilities (SNF) or swing beds providers, CMS also announced it will delay the Minimum Data Set (MDS) 3.0 v1.18.1 release which had been scheduled for October 1, 2020. CMS did not provide a new date, but questions may be directed to the following CMS mailbox: MDSCodinganswers@cms.hhs.gov.
CMS is providing ongoing updates on how it will delay and re-prioritize survey activities. In a memorandum to state survey agencies on March 23, CMS is prioritizing surveys by authorizing modification of timetables and deadlines for three weeks. During this timeframe, CMS indicates the following types of surveys will be prioritized and conducted:
- Complaint/facility-reported incident surveys: State survey agencies (SSAs) will conduct surveys related to complaints and facility-reported incidents (FRIs) that are triaged at the Immediate Jeopardy (IJ) level. A streamlined Infection Control review tool will also be utilized during these surveys, regardless of the Immediate Jeopardy allegation.
- Targeted Infection Control Surveys: Federal CMS and State surveyors will conduct targeted Infection Control surveys of providers identified through collaboration with the Centers for Disease Control and Prevention (CDC) and the HHS Assistant Secretary for Preparedness and Response (ASPR). They will use a streamlined review checklist to minimize the impact on provider activities, while ensuring providers are implementing actions to protect the health and safety of individuals to respond to the COVID-19 pandemic.
- Self-assessments: The Infection Control checklist referenced above will also be shared with all providers and suppliers to allow for voluntary self-assessment of their Infection Control plan and protections.
CMS also released a Frequently Asked Questions piece related to provider enrollment. This includes providing temporary Medicare billing privileges and waiving certain screening requirements during the duration of the emergency. There are toll-free numbers at each of the MACs to process these enrollments.
Next Steps:
- Watch CLA’s series of COVID-19 Livestreams for weekly information and insights.
- Stay up-to-date by frequently checking CLA’s COVID-19 resource page for articles and webinars.
- Reach out to your CLA advisor if we can help.
Jennifer Boese is the Director of Health Care Policy at CLA. She is a highly successful public policy, legislative, advocacy and political affairs leader, including working in both the state and federal government as well as the private sector. She brings over 20 years of government relations and public policy knowledge with her to CLA. Well over half of her career has been spent dedicated to health care policy and the health care industry, affording her a deep understanding of the health care market and environment, health care organizations and health care stakeholders. Her role at CLA is to provide thought leadership, policy analysis and strategic insights to health care providers across the continuum related to the industry's ongoing transformation towards value. A key focus of that work is on market innovations and emerging payment models. Her goal is to help CLA clients navigate and thrive in an increasingly dynamic health care environment.
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