SPECIAL BULLETIN COVID-19 #164: Update on CARES Act-funded Payments to Nursing Facility Providers for Staff Testing Costs
This bulletin provides an update on the final reconciliation activity related to nursing facility staff COVID-19 testing payments authorized under Secretarial Orders No. 2 and No. 4. This bulletin should be reviewed in conjunction with Special Bulletin COVID-19 #146 Update on CARES Act-Funded Payments to Nursing Facility Providers and Availability of Extension Funding and Special Bulletin COVID-19 #129 Reporting Requirements and Financial Support to Nursing Homes under Secretarial Order No. 2.
Background on Final Reconciliation Under Original CARES Act Funding
As established under NCDHHS Secretarial Order No. 2 and extended under NCDHHS Secretarial Order No.4, NC Medicaid administers CARES Act resources to fund COVID-19 testing of nursing facility staff and other healthcare personnel. In previous related bulletins, NC Medicaid communicated the intent to conduct a final reconciliation of actual costs paid for testing activity performed between Aug. 7, 2020 and Dec. 30, 2021, against projected cost payments made to providers. Participating providers were required to submit final “Actual Cost cases” for dates under the initiative’s original funding (“Original Funding”) to NC Medicaid by March 1, 2021.
Overview of Final Reconciliation Steps
- After the Actual Cost case submission deadline referenced above, NC Medicaid reconciled approved Actual Cost submissions under Original Funding against previously paid projected cases.
- To offset any negative balance resulting from this reconciliation, NC Medicaid then evaluated the authorized pending payments under CARES Act Extension funding owed to the provider through NC Tracks’ 2021 Checkwrite #12.
- Any remaining negative balance after this offset has been identified as the provider’s Final Cares Act Negative Balance and will be communicated through the Tentative Demand Notice reference below.
Final Reconciliation Demand Communication
Starting the week of April 19, 2021, NC Medicaid will email a Tentative Demand Notice to impacted providers.
- This notice will include detail on the final reconciliation process, the provider’s identified balance and follow-up steps available to providers for balance inquiries.
- NC Medicaid will send this notice through email to the identified point of contact for financial submissions to the COVID-19 Testing Portal.
Understanding Your Facility’s Negative Balance
A facility may review its CARES Act submission history through the COVID-19 Testing: Nursing Home Reporting Portal’s Submitted Case History feature now available on the home page.
Facilities should also review the previous Special Bulletins referenced at the beginning of this bulletin and related training materials.
Disputing the Negative Balance Determination
- If a provider disagrees with NC Medicaid’s negative balance determination, they may provide evidence disputing the balance.
- Any evidence disputing the State-determined negative balance and any resulting reconciliation with the State must be finalized within 30 calendar days of the Tentative Demand Notification date.
- A provider is responsible for initiating any request to dispute the negative balance, following the instructions provided in the Tentative Demand Notice.
- After 30 days from the date of the Tentative Demand Notice, the State will issue a formal demand letter and remaining negative balances will be scheduled for recoupment.
The Recoupment Process
- To recoup any final negative balances from Medicaid-enrolled providers, the State will issue an Accounts Receivable (AR) recoupment through NCTracks, to take effect through a subsequent checkwrite.
- Providers who are not enrolled in Medicaid will receive instructions in the provider’s Tentative Demand Notice.
Providers who have independently identified an overpayment to date are obligated under the terms of the NC Medicaid Provider Participation Agreement to notify NC Medicaid of any identified anticipated overpayment.
Providers may communicate this by emailing Medicaid.ProviderReimbursement@dhhs.nc.gov.
Failure to communicate facility-identified overpayments, may result in recoupment with penalty.
For additional information about Secretarial Orders 2 and 4 and related payments, please visit NC Medicaid’s COVID-19 Status and Reporting page.