Many radiologists are seeing a 50% or more reduction in procedures since the outset of COVID-19.
What assistance is available to weather the storm?
The Centers for Medicare & Medicaid Services stated that they have delivered almost "$34 billion in the past week to the healthcare providers". How are you able to take advantage of this funding? This article will discuss two government funded programs to assist radiologists and radiology groups during the COVID-19 pandemic.
First Program: Medicare Advanced Payment Program
Radiologist across the United States are complying with Federal Regulations and have stopped all non-essential procedures. Seema Verma, CMS Administrator, stated that providers "shouldn’t be penalized for doing the right thing.” This Program can be used to survive the economic crisis caused by the pandemic.
The first program is the Medicare Advanced Payment Program. This program allows you to get advanced payment on future Medicare claims. Any provider is eligible who:
- Has billed Medicare in the past 180 Days
- Who is not in bankruptcy
- Is not under active medical review or program integrity investigation
- Does not have any delinquent Medicare overpayments
You can request up to 100% of your Medicare payment amount for a three-month period. Medicare states "they will process your request and issue payment within seven (7) calendar days of receiving the request". Although, depending on how many requests CMS receives, it could take longer.
Repayment will begin 120 days after the advanced payment is made and must be fully repaid within 210 days. You pay the money back via your Medicare claims. Thus, instead of receiving payments for newly submitted claims, the advance payment balance is reduced via payment offset. This is automatic.
If you want to apply for the Medicare Advanced Payment Program, follow this guide provided by the CMS. This guide will break down the necessary steps on how to submit your request and the necessary components.
Second Program: CARES Act Provider Relief Fund
The second program is the CARES Act Provider Relief Fund. The CARES Act will be providing "$100 billion in relief funds to hospitals and other healthcare providers" as part of the stimulus bill recently passed. The HHS states that the purpose of this program is "to support healthcare-related expenses or lost revenue attributable to COVID-19". The HHS will be provided the initial 30 billion as of April 10th to eligible providers. An additional 70 billion will be provided after this first distribution.
As a radiologist, you may have not seen a drop in revenue in March. However, you may in April and for a few months thereon due to the lack of non-essential procedures and scans (e.g. screening mammograms) taking place during this time. It is important to note that the HHS Administration will be providing this money first to providers "in areas particularly impacted by the COVID-19 outbreak, rural providers, providers of services with lower shares of Medicare reimbursement or who predominantly serve the Medicaid population, and providers requesting reimbursement for the treatment of uninsured Americans". Due to the funds being limited, applying for both programs would be advised.
According to the HHS, any provider is eligible who:
- Have Received Medicare fee-for-service (FFS) reimbursements in 2019
- Must agree not to seek collection of out-of-pocket payments from a COVID-19 patient that are greater than what the patient would have otherwise been required to pay if the care had been provided by an in-network provider.
- Are within heavily impacted areas of the COVID-19 pandemic and who are struggling to keep their doors open due to healthy patients delaying care and cancelled elective services
This distribution will be provided in different avenues depending on if you are a large organization, employed Radiologist, part of a Radiology group, or a single Radiologist.
What if I am a part of a radiology group?
Radiology groups will receive the relief fund payment as the billing organization. Radiologists within the group should reach out their in-house billing team or their billing partner like Dexios to identify the accounts where they should expect relief payments.
What if I am a single radiologist and not a part of a group?
Radiologist will receive a payment under the Tax Identification Number (TIN) used to bill Medicare.
If you want to request for distribution payment through the CARES Act, follow this guide provided by the HHS. This guide will break down the necessary steps on how to determine if you are able to receive this type of relief and how to receive your part of the distribution.
Third Program: Paycheck Protection Program (PPP)
We would also recommend looking into the Paycheck Protection Program (PPP) as a possible source for funds.
The Paycheck Protection Program is a loan designed to provide a direct incentive for small businesses to keep their workers on the payroll.
The program is designed to incent organizations for keeping people employed during the crisis. The SBA will forgive the PPP loans if all employees are kept on the payroll for eight weeks and the loan is used for payroll, rent, mortgage interest, or utilities.
You can apply through any existing SBA 7(a) lender or through any federally insured depository institution, federally insured credit union, and Farm Credit System institution that is participating. Your bank is a great place to start the process.
The Paycheck Protection Program will be available through June 30, 2020. Right now it is not fully funded but Congress is working on legislation to add funds. There is no reason not to start the process now. Don't wait for the funding to be complete.
The following entities affected by Coronavirus (COVID-19) may be eligible:
- Any small business concern that meets SBA’s size standards (either the industry based sized standard or the alternative size standard)
- Sole proprietors, independent contractors, and self-employed persons
The government has put in place several different programs to assist healthcare providers. More news to come as more funding may be coming as well. It is encouraging to know that your losses from COVID-19 will be mitigated. All of these programs can assist providers to restore your practice during this difficult time.
What is the difference between these programs? Great question. The CMS will be handling the Medicare Advanced Payment Program (MAPP) and the HHS will be handling the CARES Act Provider Relief Fund. The SBA will be handling PPP.
The PPP does not have to be paid back if employees are kept on staff and funding is used in an approved manner. MAPP does have to be paid back, but can be extended into a loan. The Provider Relief Fund does not have to be paid back if you follow the attestation procedures. Please see each program for details.