Medicare Compliance & Reimbursement

Stay on top of PPP deadlines and accelerated payment bill due dates.

If the fallout from COVID-19 has wreaked havoc on your Medicare practice, there’s still time to apply for a Paycheck Protection Program (PPP) loan. Recent legislation offers applicants more time with a deadline extension.

Review the Latest PPP Loan Update

On March 30, President Biden signed the PPP Extension Act of 2021, which extended the deadline to apply for PPP loans from March 31 to May 31. “It is a bipartisan accomplishment,” Biden said when signing the bill into law. “Nearly 90,000 business owners are still in line, and there’s money left.”

Reminder: “The law doesn’t provide the PPP with any additional funding. However, $7.25 billion in additional funding was recently provided in the American Rescue Plan Act,” notes Emir Hodzic with VonLehman & Co.

“This extension will provide borrowers with much-needed additional time to submit their PPP loan application prior to the end of the program,” praises BKD in online analysis. As of April 12, the Small Business Administration (SBA) had approved about 4.4 million PPP loans totaling $232.8 billion, SBA says.

“The law also gives the Small Business Administration (SBA) an additional 30 days — through June 30, 2021 — after the extended application deadline to complete its processing of applications,” Hodzic explains. “The SBA has a backlog of applications because of a variety of factors, including coding errors,” he notes.

Caution: May 31 is Memorial Day, law firm Dykema Gossett points out in online analysis of the new law. “It is unfortunate that the last day to submit PPP Loan applications is Memorial Day,” the firm notes. “This is not really a two-month extension as borrowers will need to make sure their applications are in by Friday, May 28, before the start of the long Memorial Day holiday weekend.”

Plus, if your PPP application has been derailed by SBA error messages, act immediately, Dykema Gossett urges. “You should work with your lender now to get it cleared up, as you do not want to be dealing with those issues in May,” it says.

Feds Offer New CAAP Recoupment Guidance

While more funds may be coming available for providers via PPP on one hand, some practices are facing repayment of COVID-19 accelerated and advance payments (CAAPs) on the other.

“If you received an accelerated or advance payment, [the Centers for Medicare & Medicaid Services] will begin to recoup any outstanding balance from any payments due to you from your Medicare claims,” CMS says in an April 1 MLN Matters article. “This began as soon as March 30, 2021, depending upon the 1 year anniversary of when you received your first payment.”

How it works: After the one-year mark, “Medicare will automatically recoup 25 percent of Medicare payments otherwise owed to the provider or supplier for eleven months,” CMS explains on its CAAP webpage. “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 accelerated or advance payment during this time-period (a total of 29 months), CMS will issue demand letters requiring repayment of any outstanding balance, subject to an interest rate of four percent consistent with the Continuing Appropriations Act, 2021.”

For Part A providers receiving periodic interim payments (PIP), however, “we won’t include CAAPs in the reconciliation and settlement of final cost reports,” CMS says in the MLN Matters article. “Instead, we’ll recoup from your periodic interim payments.”

Watch out: Even if you didn’t receive any payments under your National Provider Identifier (NPI) or Provider Transaction Access Number (PTAN), that doesn’t necessarily mean you’re absolved from the repayment process. “Recoupment of payments can also be made from ‘affiliated providers,’” HHH Medicare Administrative Contractor (MAC) CGS says in new questions-and-answers about the repayments. “An affiliated provider is a provider that shares the same Tax Identification Number (TIN) and/or is noted as part of a Hospital Group (i.e., sub-units).”

You can identify the CAAP take-backs on the remittance advice, CGS advises. For Part A, “all non-settlement (non-PIP) recoupments will be reported with ‘WO’ and will appear with the transaction number, beginning with ‘CVD,’” the MAC explains.

Part B providers “will be assigned a specific Accounts Receivable (AR) number” or transaction number that starts with “CVD” and reported in tandem with “WO,” too, Part B MAC Novitas Solutions indicates.

Heads up: On April 12, Part B MAC Palmetto GBA indicated that it would be updating transaction numbers a little differently. “A new transaction number with a format starting ‘CVDA’ will appear on the remittance advice for any recoupment activity related to CAAP repayment. This new transaction number will replace the old transaction number formatted with ‘CVD’ that was previously communicated to providers on October 16, 2020,” Palmetto says.

Medicare providers under both Palmetto jurisdictions, including Parts A, B, and HHH, can expect an email explaining the change and must use the new transaction number to access CAAP repayment data with the MAC, according to the release.

At press time, none of the other MACs had updated with an alert, so this change may be specific to Palmetto GBA.

Don’t forget: “The repayment of advance payments is not an eligible use of Provider Relief Funds,” cautions consulting firm The Health Group in Morgantown, West Virginia.

Resource: More PPP details are at www.sba.gov/funding-programs/loans/covid-19-relief-options/paycheck-protection-program. The three-page CAAP MLN Matters article is at www.cms.gov/files/document/se21004.pdf.