However, if the hospice provider is financially unable to repay the over-payment within the standard period without experiencing hardship, they may request an extended repayment schedule. Here's a general outline of the steps and considerations for a hospice provider seeking an ERS:
- Assess Eligibility: The service provider must first determine whether it is eligible for an ERS based on specific criteria set out by Medicare. The criteria could involve the provider's financial condition and the amount of the over-payment.
- Understand the Regulations: Providers should refer to the Centers for Medicare & Medicaid Services’ (CMS) regulations, which outline the conditions and process for applying for repayment plans. These regulations can change, so it's important for providers to ensure they have the most current information.
- Prepare Documentation: The hospice provider will need to prepare extensive documentation to support their ERS request. This may include detailed financial statements and an explanation of why the over-payment cannot be repaid in full by the due date.
- Submit the Request: The ERS request, along with all supporting documentation, must be submitted to the appropriate Medicare contractor. It's important to follow the submission guidelines carefully to avoid delays.
- Negotiation: Sometimes, there may be a negotiation process where the Medicare contractor reviews the proposal, the documentation, and possibly requests additional information.
- Compliance with Terms: If an ERS is granted, the hospice provider must comply with the terms of the repayment agreement, which includes the schedule of payments and possibly interest.
- Regular Updates: Providers may be required to submit updated financial statements at regular intervals to demonstrate their continuing inability to repay the over-payment in full.
- Potential Actions for Noncompliance: If the hospice provider fails to meet the terms of the ERS, Medicare can take actions such as withholding Medicare payments or revoking the provider’s Medicare billing privileges.
It's important for hospice providers to seek advice from a healthcare attorney or a consultant who specializes in Medicare billing to ensure compliance with Medicare rules and regulations when applying for an ERS. Since specific policies and forms can vary by region and are subject to change, it's essential to refer to the current and local CMS guidelines for the most updated and relevant information.
