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COVID-19: Expansion of the Medicare Accelerated and Advanced Payment Program

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On Saturday, March 28, 2020, the US Centers for Medicare & Medicaid Services (CMS) announced an expansion of its Accelerated and Advance Payment Program (APP) for Medicare providers as part of the CARES act passed by the federal government.
April 1, 2020

On Saturday, March 28, 2020, the US Centers for Medicare & Medicaid Services (CMS) announced an expansion of its Accelerated and Advance Payment Program (APP) for Medicare providers as part of the CARES act passed by the federal government.1 CMS stated the reason for this expansion was to ensure healthcare providers had the resources they needed to combat the COVID-19 global pandemic.2

Accelerated and advance Medicare payments provide emergency funding and address cash flow issues when there is a disruption in claims submission and/or claims processing.3 The accelerated and advance Medicare payments are based on historical Medicare payments for the individual practice.4 

The expansion of the APP5 is only for the duration of the public health emergency. CMS is authorized to provide accelerated or advance payments, interest-free, during the period of the public health emergency to any Medicare provider/supplier who submits a request to the appropriate Medicare Administrative Contractor (MAC) and meets the required qualifications. These providers/suppliers include hospitals, doctors, durable medical equipment suppliers, and other Medicare Part A (providers) and Medicare Part B (suppliers).

To qualify for accelerated or advance payments, the provider or supplier must:

  • Have billed Medicare for claims within 180 days immediately prior to the date of the 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.

Providers and suppliers who qualify for accelerated and advance payments will be asked to request a specific amount using an Accelerated or Advance Payment Request Form. Most providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three-month period. Inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals are able to request up to 100% of Medicare payment amount for a six month period.

Providers and suppliers can submit claims as they need after the issuance of the first accelerated/advance payment and will receive full payments for their claims for the first 120 days. Repayment of these accelerated and advance Medicare payments will begin 120 days after the date of issuance of the payment. After the end of the 120 day period, every claim submitted by the provider/supplier will be offset from the new claims to repay the accelerated/advance payment and will automatically reduce the provider’s/supplier’s outstanding accelerated/advance payment balance by the claim payment amount.

Most hospitals including inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and critical access hospitals will have up to one year from the date the accelerated payment was made to repay the balance of their outstanding accelerated/advance payment balance. At the end of one year, MACs will send a request for repayment of the outstanding accelerated/advance payment balance to be repaid by direct payment if an outstanding balance exists. The same process will occur within a 210 day period for all other Part A providers not listed above and Part B suppliers For Part A providers who receive Period Interim Payment (PIP), the accelerated payment reconciliation process will happen at the final cost report process - 180 days after the fiscal year closes.

To request accelerated or advance payments from CMS, providers and suppliers should first complete and submit a request form. The accelerated/advance payment request forms vary by MAC and can be found on each MAC’s website. Providers and suppliers can locate their designated MAC here.

1  https://homehealthcarenews.com/2020/03/cms-expands-medicare-accelerated-payment-program-to-help-with-covid-19-cash-flow-challenges/
2  https://www.cms.gov/newsroom/press-releases/trump-administration-provides-financial-relief-medicare-providers
https://www.cms.gov/newsroom/press-releases/trump-administration-provides-financial-relief-medicare-providers
4  https://www.cms.gov/newsroom/press-releases/trump-administration-provides-financial-relief-medicare-providers
5  https://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf

 

Readers should not act upon information presented without individual professional consultation.

Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.

 

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