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Accelerated and Advance Payments Programs for Medicare Providers and Suppliers

In order to increase cash flow to providers of services and suppliers impacted by the 2019 Novel Coronavirus (COVID-19) pandemic, the Centers for Medicare & Medicaid Services (CMS) has expanded their current Accelerated and Advance Payment Program to a broader group of Medicare Part A providers and Part B suppliers. The expansion of this program is only for the duration of the public health emergency as reflected by the recent passage of the CARES Act.

Accelerated/Advance Payments

An accelerated/advance payment is a payment intended to provide necessary funds when there is a disruption in claims submission and/or claims processing, as well as in national emergencies or natural disasters. CMS is authorized to provide accelerated or advance payments 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.

Eligibility & Process

Eligibility: To qualify for accelerated/advance payments the provider/supplier must:
  1. Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider's/supplier's request form,
  2. Not be in bankruptcy,
  3. Not be under active medical review or program integrity investigation, and
  4. Not have any outstanding delinquent Medicare overpayments.
Amount of Payment: Qualified providers/suppliers will be asked to request a specific amount using an Accelerated or Advance Payment Request form provided on each MAC's website. 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 the Medicare payment amount for a six-month period. Critical access hospitals (CAH) can request up to 125% of their payment amount for a six-month period.

Processing Time: Each MAC will work to review and issue payments within seven (7) calendar days of receiving the request.

Repayment: CMS has extended the repayment of these accelerated/advance payments to begin 120 days after the date of issuance of the payment. The repayment timeline is broken out by provider type below:
  1. Inpatient acute care hospitals, children's hospitals, certain cancer hospitals, and Critical Access Hospitals (CAH) have up to one year from the date the accelerated payment was made to repay the balance.
  2. All other Part A providers and Part B suppliers will have 210 days from the date of the accelerated or advance payment was made to repay the balance.
Recoupment and Reconciliation:
  1. The provider/supplier can continue to submit claims as usual after the issuance of the accelerated or advance payment; however, recoupment will not begin for 120 days. Providers/ suppliers will receive full payments for their claims during the 120-day delay period. At the end of the 120-day period, the recoupment process will begin and every claim submitted by the provider/supplier will be offset from the new claims to repay the accelerated/advanced payment. Thus, instead of receiving payment for newly submitted claims, the provider's/supplier's outstanding accelerated/advance payment balance is reduced by the claim payment amount. This process is automatic.
  2. The majority of 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. That means after one year from the accelerated payment, the MACs will perform a manual check to determine if there is a balance remaining, and if so, the MACs will send a request for repayment of the remaining balance, which is collected by direct payment. All other Part A providers not listed above and Part B suppliers will have up to 210 days for the reconciliation process to begin.
  3. For the small subset of 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).
Accelerated/Advance Payment Request forms vary by contractor and can be found on each individual MAC's website. Complete an Accelerated/Advance Payment Request form and submit it to your servicing MAC via mail or email. CMS has established COVID-19 hotlines at each MAC that are operational Monday - Friday to assist you with accelerated payment requests. You can contact the MAC that services your geographic area. To locate your designated MAC, refer to this website linked here.

$100 Billion of Additional Funding to Hospitals and Doctors

An additional provision of the CARES Act directs $100 billion to the Public Health and Social Services Emergency Fund. These funds, at the direction of the Secretary of Health and Human Services, will be allocated to hospitals facing critical shortages as a result of the COVID-19 pandemic. The funds average about $108,000 per hospital bed in the United States.

Although many questions remain, hospitals will be able to apply for assistance for a range of coronavirus-related expenses, including temporary structures and medical supplies. Funding cannot be received for expenses that will otherwise be reimbursed. This funding may also be directed to replace revenue lost as a direct result of the pandemic. Both for-profit and not-for-profit hospitals are eligible to receive assistance. Additionally, other entities that diagnose, test, or provide care for COVID-19 patients may receive funding.

In a recent letter by the Medical Group Management Association (MGMA), an urgent request was made to the Department of Health and Human Services to establish procedures to ensure the timely and rapid distribution of direct payments to the doctors most impacted by the COVID-19 crisis. Because most routine outpatient procedures have ceased, doctors from all fields are facing critical revenue shortfalls while having to maintain significant cash outlays. As a result, the MGMA recommended the following mechanisms to assist these doctors:
  1. Prepayments to enrolled suppliers not subject to recoupment; 
  2. An immediate increase in the Part B conversion factor through the end of the year to offset lost revenues from Medicare patients deferring care; and 
  3. An expedited grant process designed for those practices that have the resources to interface directly with the Department in the weeks ahead.
Much uncertainty still remains; however, the Secretary must submit answers to Congress starting in 60 days to provide additional clarification on the ways in which these funds are being allocated. We will continue to monitor this situation for updates and clarifications and provide that information as it come available.

If you have any additional questions, please feel free to reach out at any time.

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