Eyeworld

N EWS 26 | EYEWORLD | MAY 2020 COVID-19 NEWS YOU CAN USE Program. Investigations that would disqualify a physician from receiving these payments are program integrity and fraud investigations, she said. Targeted probe and educate (TPE) and RAC audits do not disqualify a physician, and those under investigation will have received notice from a program integrity contractor, she said. Group practice application Addressing whether a group practice can apply for an advance payment using its taxpayer identification number (TIN) or if each individ- ual physician needs to apply, Ms. McCann said that CMS indicated to the AMA that advance payments must be requested at the individual national provider identifier (NPI) level, as this is how the MACs calculate the amount of pay- ments to be advanced. If everyone in a group wants to request an advance payment, each physician would need to complete a form with their NPI. The payments will be made in the same way other Medicare payments are made; if the group's claims are paid to a particular TIN, that is where the advance payment will be sent. However, it has been reported by ASOA mem- bers that individual MACs are only requiring the TIN for the group practice. "We encourage you to contact your MAC," Ms. McCann said. Administrative appeal rights Finally, she addressed administrative appeal rights, noting that the MACs determine whether the physician qualifies for the advance payment and the amount they are eligible to receive. These determinations cannot be appealed. But physicians can still resubmit and/or appeal indi- vidual claims that are denied. Other programs During her presentation, Ms. McCann briefly touched on the small business loans (Paycheck Protection Program) that were also made available through the CARES Act. Initially, the Paycheck Protection Program authorized up to $349 billion in forgivable loans to small businesses to pay their employees during the pandemic. New legislation, the "Paycheck Protection Program and Health Care Enhancement Act," has already been signed into law and replenishes and cash position. The most important required information is that the request is based on the COVID-19 emergency and a signature of an authorized person should be included. Requested loan amount In terms of calculating the requested amount, she said that physician practices do not have to calculate amounts. All MACs have been in- structed to use the physician's claims for the pe- riod from October–December 2019 as the basis for the maximum advance payment amount, Ms. McCann said. Physicians may also choose to request less than 100% of the 3 months and could have the option of asking for 50% now and 50% at a later time. Recoupment process In terms of the recoupment process, recoup- ment of advance payments will begin 120 days after the funds have been disbursed and will be taken from claims submitted at that time until the full amount has been repaid. Physicians may request to repay the funds, or a portion of the funds, directly instead of them being recouped through claims submissions, and they may also request that payments be made on less than 100% of the claims during the repayment period. With this program, you do have to pay back all of the money, Ms. McCann emphasized, unlike with the Paycheck Protection Program. Interest Ms. McCann said that no interest is charged on COVID-19 advance payments that are repaid within 210 days of the disbursement. If repay- ment within this timeframe is a hardship for the practice, physicians can request that the MAC provide an extended repayment plan. Interest is charged on extended repayment plan payments at 10.25% per the statute. CMS is checking with their general counsel regarding any flexibility they might have in this regard, but at this time it appears it would require a technical correction by Congress in the COVID-19 fourth stimulus package. Disqualification Ms. McCann also addressed concerns about disqualification from the Advance Payment continued from page 24

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