Home Health & Hospice Week

Payments to bankrupt providers were quickly remedied.>

For once, the HHS Office of Inspector General is giving Medicare a passing grade on something.

The federal watchdog agency examined a sample of 100 COVID-19 Accelerated and Advance Payments, plus nine payments made to providers that had declared bankruptcy — which wasn’t supposed to happen.

Congress set four CAAP criteria when it instituted the relief program, the OIG notes. A provider must:

(1) not be under bankruptcy,

(2) have billed Medicare for claims within 180 days immediately before the date of signature on the provider’s request form,

(3) not be under active medical review or program integrity investigation, and

(4) not have any outstanding delinquent Medicare overpayments.

The more-than $100 billion in CAAP funds “were issued in a short period of time, thus increasing the risk of improper payments,” the OIG notes.

However, “CMS generally made CAAP Program payments to providers in compliance with the CARES Act and other Federal requirements” and “appropriately made CAAP Program payments to all 100 providers” that hadn’t declared bankruptcy, the OIG praises.

“For the nine providers under bankruptcy, CMS did not send a CAAP Program payment to six of the providers,” the OIG found. However, CMS did make CAAP payments to three “because two [Medicare Administrative Contractors] did not correctly match the provider’s request against their bankruptcy databases, and one MAC did not update its bankruptcy database based on bankruptcy information that was provided by CMS prior to approving the CAAP Program payment request,” according to the report.

Nice save: “For the three CAAP Program payments made to providers under bankruptcy, the MACs immediately identified their errors after the payment and recovered the improper payments,” so the OIG doesn’t recommend any changes, it notes. v

Note: The OIG’s CAAP report is at https://oig.hhs.gov/oas/reports/region5/52000053.pdf.