The purpose of this message is to clarify the guidance for Error Updates related to FY'20 Retainer Days. According to guidance provided by CMS, the Guardrails apply retroactively to March 13, 2020. This means that a provider who has requested or used Retainer Days, and has either laid-off/furloughed staff or received federal financial assistance through a SBA loan or the Payroll Protection Program, etc., may be subject to a recoupment of the Retainer Day payment in the future. It is important that the DDA understands your use of retainer days, so you must attest to the guardrails for every quarter in which retainer days were requested retroactive to March 13, 2020. DDA is still working through the logistics of the recent CMS guidance but wanted to alert providers of the potential recoupment in the future. The deadline for submitting the error updates will be extended one week to April 23, 2021.
