CMS Expands Accelerated/Advanced Payments during COVID-19 Public Health Emergency

On April 8, 2020, the Centers for Medicare & Medicaid Services (CMS) announced that it will expand the Accelerated/Advance Payment Program (the “Program”) for a broader group of Medicare Part A providers and Part B suppliers during the COVID-19 Public Health Emergency. This expansion will only be effective for the duration of the COVID-19 emergency.

Please note that this Program funding is separate from the $100 billion hospital fund established by the Coronavirus Aid, Relief, and Economic Security (C.A.R.E.S.) Act. We have summarized the key facts from the Program below. For more details and the step-by-step guide on how to request funds through this Program, please review the fact sheet CMS provided for the Program available here .

To qualify for advanced payment this Program, a provider/supplier must:

(i)     Have billed Medicare for claims within 180 days immediately prior to the signature on the advanced payment request form;
(ii)   Not be subject to bankruptcy;
(iii)  Not be under any active medical review or program integrity investigations; and
(iv)  Not have any outstanding delinquent Medicare overpayments.

Additional key facts are as follows:

  • Providers/suppliers must submit an advanced payment request form to their respective Medicare Administrative Contractor (MAC). Request forms will vary for each MAC, and can be found on each individual MAC’s website. To locate a provider /supplier’s MAC, refer to the CMS chart available here.

  • Providers/suppliers can request an advance for up to 100% of each Medicare payment for a three (3) month period. Inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals can request up to 100% of payments for a six (6) month period. Critical access hospitals (CAHs) can request up to 125% of payments for a six (6) month period.

  • CMS extended repayment of these advanced payments to 120 days after the issuance of payment. Inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and CAHs have up to one (1) year from the issuance of the advanced payment. However, all other qualified Part A providers and Part B suppliers must repay the balance 210 days from the issuance of the advanced payment.

This alert is intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have. We are fully operational during this pandemic and stand ready to assist as you navigate this ongoing and developing COVID-19 situation. Please do not hesitate to contact any member of our response team with your questions and concerns.