[vc_toggle title=”What is the CARES Act?” style=”round” el_class=”myFaqSingle”]The CARES Act is the Coronavirus Aid, Relief, and Economic Security Act passed by the U.S. Congress and signed into law by President Trump on March 27, 2020 to provide emergency assistance and health care response for individuals, families, and businesses affected by the 2020 Coronavirus pandemic.[/vc_toggle][vc_toggle title=”What are small business interruption loans?” style=”round” el_class=”myFaqSingle”]Small business interruption loans are loans made under Section 7(a) of the Small Businesses Act. The CARES Act has increased the eligibility of those able to receive these loans to any business that employs less than 500 employees. The CARES Act further allows any payments on the loan to be deferred for 6 to 12 months and will provide forgiveness of some or all amounts owed on the loan for the covered period if certain conditions are met.[/vc_toggle][vc_toggle title=”What is the Covered Period of the Loan?” style=”round” el_class=”myFaqSingle”]CARES Act designates the qualified period beginning February 15, 2020 and ending June 30, 2020.[/vc_toggle][vc_toggle title=”Will my center qualify for this loan?” style=”round” el_class=”myFaqSingle”]Maybe. Regent is currently working with legal experts to determine whether the factual circumstances at each Regent center will allow the Center to qualify for this loan. It is expected that Treasury Secretary, Steve Mnuchin, will release further guidance by Friday April 3 that we expect will provide further clarity on whether or not some Centers qualify.[/vc_toggle][vc_toggle title=”Where can we apply for the loan?” style=”round” el_class=”myFaqSingle”]Any bank that is qualified to make a small business loan. The Secretary of the Treasury is going to greatly expand the number of banks that are qualified to make these loans. It is expected that any center that qualifies for a loan will be able to receive the loan from the bank it currently has a relationship with.[/vc_toggle][vc_toggle title=”How much is the loan amount qualified businesses receive?” style=”round” el_class=”myFaqSingle”]CARES Act authorizes a loan amount equal to the lesser of, $10 Million or average total monthly payments for allowed payroll costs from Feb. 15, 2019 to June 30, 2019, multiplied by 2.5.[/vc_toggle][vc_toggle title=”What qualifies as Payroll Costs?” style=”round” el_class=”myFaqSingle”]The sum of the following qualifies as payroll costs. Regent has provided a worksheet that each Center’s lead accountant is expected to fill out by 3/31 that will allow us to calculate the exact loan amount for every Center.

• Salary, wages, commission, or similar compensation
• Paymentes for parental, family, medical, or sick leave
• Allowance for dismissal or separation leave
• Payments required for provisions of group health benefits
• Payment of state of local taxes
• Payment of any retirement benefits
• Payment to an independent contractor or sole proprietor up to $100K

*note – any individual’s compensation amount is capped at $100K/year (in other words, when calculating the loan amount, for any employee making over $100K/year, you can only add $8,333 per month for that employee)[/vc_toggle][vc_toggle title=”What are the restrictions on what the loan can be used for?” style=”round” el_class=”myFaqSingle”]The loan can only be used to pay for the following expenses:

• Payroll costs
• Costs related to continuing group health benefits
• Salaries, commission, wages, etc.
• Interest payments on a mortgage
• Rent
• Utilities
• Interest on debt incurred prior to Feb. 15, 2020

[/vc_toggle][vc_toggle title=”How much of the loan will be forgiven at the end of the covered period?” style=”round” el_class=”myFaqSingle”]The loan will be forgiven in an amount equal to the sum of the allowable expenses for the covered period of February 15, 2020 – June 30, 2020. The amount forgiven will be reduced based on the following:

Number of Employees: Avg. # of employees per month from Feb. 15 – June 30, 2020 / Avg. # of employees per month from Feb. 15 – June 30, 2019 (or Jan 1 – Feb. 29, 2020)
Amount will be reduced by the % determined by the above ratio
Avg. # of employees = avg. # of employees for each pay period falling within a month
Reduction in salary and wages: Total salary and wage reductions on any employee making less than $100K/year greater than 25% during the most recent full quarter

There will be no penalties for reductions made between Feb. 15 and 30 days following enactment of the CARES Act (April 26) if the reduction is eliminated by June 30.[/vc_toggle][vc_toggle title=”What is the process for receiving debt forgiveness?” style=”round” el_class=”myFaqSingle”]Documentation of all expenses must be provided to the lender. The lender then has 60 days to determine whether or not the borrower qualifies for loan forgiveness, and what that amount is eligible for forgiveness.[/vc_toggle]

Eligibility & Process

[vc_toggle title=”Eligibility” style=”round” el_class=”myFaqSingle”]To qualify for advance/accelerated payments the provider/supplier must:

1. Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form,
2. Not be in bankruptcy,
3. Not be under active medical review or program integrity investigation, and
4. Not have any outstanding delinquent Medicare overpayments.

[/vc_toggle][vc_toggle title=”Amount of Payment” style=”round” el_class=”myFaqSingle”]Qualified providers/suppliers will be asked to request a specific amount using an Accelerated or Advance Payment Request form provided on each MAC’s website. Most providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three-month period. Inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals are able to request up to 100% of the Medicare payment amount for a six-month period. Critical access hospitals (CAH) can request up to 125% of their payment amount for a six-month period.[/vc_toggle][vc_toggle title=”Processing Time” style=”round” el_class=”myFaqSingle”]Each MAC will work to review and issue payments within seven (7) calendar days of receiving the request.[/vc_toggle][vc_toggle title=”Repayment” style=”round” el_class=”myFaqSingle”]

• Inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and Critical Access Hospitals (CAH) have up to one year from the date the accelerated payment was made to repay the balance.
• All other Part A providers and Part B suppliers will have 210 days from the date of the accelerated or advance payment was made to repay the balance.

The payments will be recovered according to the process described in number 7 below.[/vc_toggle][vc_toggle title=”Recoupment and Reconciliation” style=”round” el_class=”myFaqSingle”]

• The provider/supplier can continue to submit claims as usual after the issuance of the
  accelerated or advance payment; however, recoupment will not begin for 120 days. Providers/ suppliers will receive full payments for their claims during the 120-day delay period. At the end of the 120-day period, the recoupment process will begin and every claim submitted by the provider/supplier will be offset from the new claims to repay the accelerated/advanced payment. Thus, instead of receiving payment for newly submitted claims, the provider’s/supplier’s outstanding accelerated/advance payment balance is reduced by the claim payment amount. This process is automatic.
• The majority of hospitals including inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and critical access hospitals will have up to one year from the date the accelerated payment was made to repay the balance. That means after one year from the accelerated payment, the MACs will perform a manual check to determine if there is a balance remaining, and if so, the MACs will send a request for repayment of the remaining balance, which is collected by direct payment. All other Part A providers not listed above and Part B suppliers will have up to 210 days for the reconciliation process to begin.
• For the small subset of Part A providers who receive Period Interim Payment (PIP), the accelerated payment reconciliation process will happen at the final cost report process (180 days after the fiscal year closes).

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Step-by-Step Guide on How to Request Accelerated or Advance Payment

[vc_toggle title=”Complete and submit a request form” style=”round” el_class=”myFaqSingle”]Accelerated/Advance Payment Request forms vary by contractor and can be found on each individual MAC’s website. Complete an Accelerated/Advance Payment Request form and submit it to your servicing MAC via mail or email. CMS has established COVID-19 hotlines at each MAC that are operational Monday – Friday to assist you with accelerated payment requests. You can contact the MAC that services your geographic area. To locate your designated MAC, refer to https://www.cms.gov/Medicare/Medicare-Contracting/Medicare-Administrative- Contractors/Downloads/MACs-by-State-June-2019.pdf

CGS Administrators, LLC (CGS) – Jurisdiction 15

(KY, OH, and home health and hospice claims for the following states: DE, DC, CO, IA, KS, MD, MO, MT, NE, ND, PA, SD, UT, VA, WV, and WY)
The toll-free Hotline Telephone Number: 1-855-769-9920
Hours of Operation: 7:00 am – 4:00 pm CT

The toll-free Hotline Telephone Number for Home Health and Hospice Claims: 1-877-299- 4500
Hours of Operation: 8:00 am – 4:30 pm CT for main customer service and 7:00 am – 4:00 pm CT for the Electronic Data Interchange (EDI) Department

First Coast Service Options Inc. (FCSO) – Jurisdiction N

(FL, PR, US VI)
The toll-free Hotline Telephone Number: 1-855-247-8428 Hours of Operation: 8:30 AM – 4:00 PM ET

National Government Services (NGS) – Jurisdiction 6 & Jurisdiction K

(CT, IL, ME, MA, MN, NY, NH, RI, VT, WI, and home health and hospice claims for the following states: AK, AS, AZ, CA, CT, GU, HI, ID, MA, ME, MI, MN, NH, NV, NJ, NY, MP, OR, PR, RI, US VI, VT, WI, and WA)
The toll-free Hotline Telephone Number: 1-888-802-3898

Hours of Operation: 8:00 am – 4:00 pm CT

Novitas Solutions, Inc. – Jurisdiction H & Jurisdiction L

(AR, CO, DE, DC, LA, MS, MD, NJ, NM, OK, PA, TX, (includes Part B for counties of Arlington and Fairfax in VA and the city of Alexandria in VA))
The toll-free Hotline Telephone Number: 1-855-247-8428
Hours of Operation: 8:30 AM – 4:00 PM ET

Noridian Healthcare Solutions – Jurisdiction E & Jurisdiction F

(AK, AZ, CA, HI, ID, MT, ND, NV, OR, SD, UT, WA, WY, AS, GU, MP) The toll-free Hotline Telephone Number: 1-866-575-4067
Hours of Operation: 8:00 am – 6:00 pm CT

Palmetto GBA – Jurisdiction J & Jurisdiction M

(AL, GA, NC, SC, TN, VA (excludes Part B for the counties of Arlington and Fairfax in VA and the city of Alexandria in VA), WV, and home health and hospice claims for the following states: AL, AR, FL, GA, IL, IN, KY, LA, MS, NM, NC, OH, OK, SC, TN, and TX)

The toll-free Hotline Telephone Number: 1-833-820-6138 Hours of Operation: 8:30 am – 5:00 pm ET

Wisconsin Physician Services (WPS) – Jurisdiction 5 & Jurisdiction 8

(IN, MI, IA, KS, MO, NE)
The toll-free Hotline Telephone Number: 1-844-209-2567 Hours of Operation: 7:00 am – 4:00 pm CT

Noridian Healthcare Solutions, LLC – DME A & D

(CT, DE, DC, ME, MD, MA, NH, NJ, NY, PA, RI, VT, AK, AZ, CA, HI, ID, IA, KS, MO, MT, NE, NV, ND, OR, SD, UT, WA, WY, AS, GU, MP)
The toll-free Hotline Telephone Numbers: A: 1-866-419-9458; D: 1-877-320-0390
Hours of Operation: 8:00 am – 6:00 pm CT

CGS Administrators, LLC – DME B & C

(AL, AR, CO, FL, GA, IL, IN, KY, LA, MI, MN, MS, NM, NC, OH,
OK, SC, TN, TX, VA, WI, WV, PR, US VI)
The toll-free Hotline Telephone Numbers: B: 866-590-6727; C: 866-270-4909 Hours of Operation: 7:00 am – 4:00 pm CT[/vc_toggle][vc_toggle title=”What to include in the request form” style=”round” el_class=”myFaqSingle”]Incomplete forms cannot be reviewed or processed, so it is vital that all required information is included with the initial submission. The provider/supplier must complete the entire form, including the following:

• Provider/supplier identification information:
  • Legal Business Name/ Legal Name;
  • Correspondence Address;
  • National Provider Identifier (NPI);
  • Other information as required by the MAC.

• Amount requested based on your need:
  • Most providers and suppliers will be able to request up to 100% of the Medicare
    payment amount for a three-month period. However, inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals are able to request up to 100% of the Medicare payment amount for a six-month period. Critical access hospitals (CAH) can now request up to 125% of their payment amount for a six- month period.

• Reason for request:
  • Please check box 2 (“Delay in provider/supplier billing process of an
    isolated temporary nature beyond the provider’s/supplier’s normal billing cycle and not attributable to other third party payers or private patients.”); and
  • State that the request is for an accelerated/advance payment due to the COVID- 19 pandemic.

[/vc_toggle][vc_toggle title=”Who must sign the request form?” style=”round” el_class=”myFaqSingle”]The form must be signed by an authorized representative of the provider/supplier.[/vc_toggle][vc_toggle title=”How to submit the request form?” style=”round” el_class=”myFaqSingle”]While electronic submission will significantly reduce the processing time, requests can be submitted to the appropriate MAC by fax, email, or mail. You can also contact the MAC provider/supplier helplines listed above.[/vc_toggle][vc_toggle title=”What review does the MAC perform?” style=”round” el_class=”myFaqSingle”]Requests for accelerated/advance payments will be reviewed by the provider or supplier’s servicing MAC. The MAC will perform a validation of the following eligibility criteria:

• Has billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s or supplier’s request form
• Is not in bankruptcy
• Is not under active medical review or program integrity investigation
• Does not have any outstanding delinquent Medicare overpayments

[/vc_toggle][vc_toggle title=”When should you expect payment?” style=”round” el_class=”myFaqSingle”]The MAC will notify the provider/supplier as to whether the request is approved or denied via email or mail (based on the provider’s/supplier’s preference). If the request is approved, the payment will be issued by the MAC within 7 calendar days from the request.[/vc_toggle][vc_toggle title=”When will the provider/supplier be required to begin repayment of the accelerated/ advanced payments?” style=”round” el_class=”myFaqSingle”]Accelerated/advance payments will be recovered from the receiving provider or supplier by one of two methods:

• For the small subset of Part A providers who receive Period Interim Payment (PIP), the
  accelerated payment will be included in the reconciliation and settlement of the final cost
  report.
• All other providers and suppliers will begin repayment of the accelerated/advance payment
  120 calendar days after payment is issued.

[/vc_toggle][vc_toggle title=”Do provider/suppliers have any appeal rights?” style=”round” el_class=”myFaqSingle”]Providers/suppliers do not have administrative appeal rights related to these payments. However, administrative appeal rights would apply to the extent CMS issued overpayment determinations to recover any unpaid balances on accelerated or advance payments.[/vc_toggle]