On March 28, 2020, the Centers for Medicare & Medicaid Services (CMS) announced that it is expanding its Accelerated and Advance Payment Program for healthcare providers and suppliers participating in Medicare. CMS is expanding the program to ensure that all Medicare-participating providers and suppliers have the resources necessary to combat COVID-19. Accelerated and/or advance payments may be offered in limited circumstances, including during national emergencies. CMS acknowledged that the financial burden on providers and suppliers related to COVID-19 is a major disruption to the U.S. healthcare system and have expanded the program to respond to the disruption.
Eligibility
To partake in the Accelerated and Advance Payment Program, the provider or supplier must submit a request to the appropriate Medicare Administrative Contractor (MAC). Note that the provider or supplier must indicate that the reason for the request is for an accelerated/advance payment due to the COVID-19 pandemic. Each MAC will provide access to the form to be completed on its website.
Further, to qualify for the program, the provider or supplier must:
- Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form;
- Not be in bankruptcy;
- Not be under active medical review or program integrity investigation; and
- Not have any outstanding delinquent Medicare overpayments.
Payment Processing
During the expansion period of the Accelerated and Advance Payment Program, providers and suppliers may request a specific amount to be paid out as an accelerated or advanced payment. The amount should be specified on the Accelerated and Advance Payment Request form submitted to the appropriate MAC. Upon receiving the request, each MAC will work to review and issue payments requested within seven (7) calendar days.
Most providers and suppliers will be eligible to receive up to 100% of the Medicare payment amount for a three (3) month period. Inpatient acute care hospitals, children’s hospitals and certain cancer hospitals may request up to 100% of Medicare payments for a six (6) month period. A critical access hospital may request up to 125% of their payment amount for a six (6) month period.
Repayment
CMS will not require repayment of the accelerated/advance payment until 120 days after issuance of the accelerated/advance payment. Once the 120-day period has run, new claims submitted by the provider or supplier will be automatically offset to repay the accelerated/advance payment. Therefore, the provider will not be paid out for the new claims submitted. Instead, the claims will be used to pay back the amount received in the accelerated/advanced payment.
Generally, providers and suppliers will have up to 210 days to repay the balance of the accelerated/advance payment. Certain facilities (i.e., inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and critical access hospitals) will have up to one (1) year to repay the balance of the accelerated/advance payment. Upon the expiration of 210-day period or the one-year period, whichever applies, the MAC will review the account to determine if a balance is remaining. If so, the MAC will issue a request for repayment of the remaining balance.
Timeframe
This expansion of the Accelerated and Advance Payment Program lasts only for the duration of the COVID-19 public health emergency. Therefore, providers and suppliers should periodically check for any updates regarding COVID-19’s status as a national emergency.
Lastly, note that CMS released a fact sheet providing an overview of the expansion. In addition to an overview of the expansion, the fact sheet contains a list of MACs and the areas that they service for providers/suppliers to reference. Providers should review the fact sheet to determine if they would like to partake in the Accelerated and Advance Payment Program.
For any questions regarding the expansion of the Accelerated and Advance Payments Program, please contact Carey F. Kalmowitz, Esq., Adrienne Dresevic, Esq. or Abby Pendleton, Esq. at (248) 996-8510 or by email at ckalmowitz@thehlp.com, adresevic@thehlp.com, and apendleton@thehlp.com.