SPECIAL BULLETIN COVID-19 #146: Update on CARES Act-Funded Payments to Nursing Facility Providers and Availability of Extension Funding

Wednesday, December 30, 2020

This bulletin updates and extends NC Medicaid’s reimbursement for allowable COVID-19 testing of nursing facility staff and healthcare personnel currently established under Secretarial Orders No. 2 and No. 4. It also updates the original end date communication under Special Bulletin COVID-19 #129 Reporting Requirements and Financial Support to Nursing Homes under Secretarial Order No. 2

In support of NC DHHS’ ongoing testing recommendations, NC Medicaid has established a time-limited funding stream to support Medicaid-enrolled nursing facility providers for allowable staff testing activity costs occurring after Dec. 30, 2020. To appropriately reflect upcoming changes to testing requirements and reimbursement methodologies, NC Medicaid is dividing the testing payments into two phases:  

  • Phase 1: activities performed under the original processes aligned with Secretarial Orders 2 and 4 (Original Funding) and occurring between Aug. 7, 2020, and Dec. 30, 2020. 
  • Phase 2: testing activity occurring after Dec. 30, 2020, (Extension Funding or Extension Payments).   

All financial support under this bulletin is subject to funding availability and payments are subject to state and federal audit requirements.

Background

As established under NC DHHS Secretarial Order No. 2 and extended under NC DHHS Secretarial Order No.4, NC Medicaid manages CARES Act resources to fund COVID-19 testing of nursing home staff and other healthcare personnel. This provides updates to processes originally under Special Bulletin #129. 

Testing Payment Phase I: Updated Guidance on Payment for Testing Activity under Original Funding  

This section outlines key milestones and compliance requirements for the original payment process established in Special Bulletin #129 and communicated as the Final Reconciliation Process. This process will remain as originally communicated and will be managed separately from Phase 2 (the Extension Funding process). 

Key Milestones of Final Reconciliation and CARES Act Payments Close Out Process

Providers seeking reimbursement under Secretarial Orders No. 2 and No. 4 for allowable costs are strongly advised to review Part 1 and Part 2 COVID-19 Testing Nursing Homes: Final Reconciliation Overview for Payments Under Secretarial Order No. 2 and No. 4, training materials and technical guidance for complying with and preparing for this final reconciliation period of activities performed under the original processes prior to Dec. 31, 2020 (Phase 1).  

  • Testing Activities Covered by CARES Act under Phase 1: The Department will use available CARES Act funding to support COVID-19 testing activity allowed under Secretarial Orders No. 2 and No. 4, and occurring between Aug. 7, 2020, and Dec. 30, 2020.
  • By Jan. 11, 2021: Providers seeking reimbursement for COVID-19 testing activity under Secretarial Orders No. 2 and No. 4 must submit remaining projected or actual financial cost cases through the COVID-19 Testing: Nursing Home Reporting Portal for any allowable COVID-19 testing for which it seeks reimbursement. 
    • If a provider has previously submitted cases it does not need to resubmit a case for same period, unless otherwise directed by NC Medicaid to do so.
    • Once provider has received an invoice for testing from its lab vendor, NC Medicaid expects this invoice to be submitted as an Actual Cost case within 30 calendar days of receipt from vendor.
  • By March 1, 2021: Remaining Provider Cost Cases Submitted
    • Providers must submit any remaining Actual Cost Cases with invoices that tie back to earlier Projected Cost Cases within 30 calendar days of receipt and no later than March 1, 2021.
    • Providers submit staff roster as described below, if not otherwise submitted.

Staff Roster Submission Requirement

As part of Final Reconciliation, nursing homes that have received or seek payment must submit a completed staff roster using the established template which will be posted here submitted with its final Actual Cost Case submission, submitted no later than March 1, 2021.   

State Reconciliation of Payments

Beginning in January 2021, NC Medicaid will conduct its final reconciliation of each provider’s projected and actual costs and conduct a compliance review of payment submissions. NC Medicaid will assess if recoupment is required and communicate directly to impacted provider, as necessary. The final reconciliation process is expected to be completed by the end of March 2021.  

Overpayments

If a provider identifies an error that resulted in overpayment, the provider must communicate this immediately to Medicaid.ProviderReimbursement@dhhs.nc.gov for additional instructions, including guidance on how overpayment can be repaid. Overpayments identified by NC Medicaid can be repaid or will be recouped. Failure to notify NC Medicaid of overpayment may result in a subsequent audit. 

Testing Payment Phase II: Payment for Allowable Testing Activity that Occurs AFTER Dec. 30, 2020, under Extension Funding

NC Medicaid has established time-limited funding to support Medicaid-enrolled nursing facility providers in continuing allowable staff testing after Dec. 30, 2020. As noted above, these payments are subject to funding availability and are subject to state and federal audit requirements. Funding availability may also be impacted by changes to North Carolina’s state of emergency. These payments will be referenced as Testing Payment Extension Funding (Extension Funding or Extension Payments).

NC DHHS projects resources to be available for allowable testing through March 2021. NC Medicaid will continue to require providers to attest to the veracity of each submission, including attestation of testing compliance under the Centers for Medicare & Medicaid Services (CMS) federal testing and reporting requirements, as applicable.

Payments for Actual Costs Only

Projected Payment costs submitted for reimbursement on testing activity that occurs after Dec. 30, 2020, will not be accepted under Phase 2 of Extension Payments. NC Medicaid will only process actual costs for reimbursement for testing activity that occurs after Dec. 30, 2020. 

Reimbursement Schedule for Extension Funding Payments

Providers may request reimbursement under the Testing Payment Extension Funding by submitting the invoice of the applicable testing or point of care supply vendor through the COVID 19 Testing: Nursing Home Portal. A provider may submit an invoice as the invoice becomes available, but no later than 30 calendar days after receiving the vendor’s invoice. NC Medicaid will retire the reporting schedule requirements established under Secretarial Orders No. 2 and No.4 for Extension Funding payments. Approved Extension payments will be processed on a monthly basis on a schedule to be communicated in the webinar referenced below.

Continued use of COVID-19 Testing: Nursing Home Portal for Extension Payments  

Providers will submit Extension Payment requests through the COVID-19 Testing: Nursing Home Portal. The Portal will be modified to provide different entry points depending on dates of testing activity and NC Medicaid will review this revised functionality during the training referenced below.  

Beginning with testing activities occurring on or after Dec. 31, 2020, providers will no longer be required to report testing activity through the COVID-19 Testing: Nursing Home Portal. To receive an Extension Payment, a provider must attest to adhering to federal testing and reporting requirements or if not subject to these requirements, must provide supporting testing documentation that will be more fully described during the webinar referenced below.

NC DHHS’ position on the continuation of Secretarial Order No. 4 will be communicated separately by the Department. 

Upcoming Webinar

NC Medicaid will host a webinar on Thursday, Jan. 7, 2021, from 12 p.m. to 1 p.m. to field questions about this bulletin. To join, please use the information provided below:

Questions

Please direct questions about this bulletin to Medicaid.ProviderReimbursement@dhhs.nc.gov. For additional information about Secretarial Orders No. 2 and No. 4 and related payments, please visit NC Medicaid’s COVID-19 Status and Reporting page.