Alex JohnOn March 28, 2020, the Centers for Medicare & Medicaid Services (“CMS”) announced an expansion of its accelerated and advance payment program for health care providers and suppliers that participate in Medicare. This expansion includes changes from the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. CMS has taken this step to help combat cash flow and payment issues that providers and suppliers are facing in connection with the 2019 Novel Coronavirus (“COVID-19”).

The accelerated/advance payment program existed prior to the COVID-19 crisis.  Its purpose has been to provide necessary funds to providers and suppliers upon a disruption in the submission or processing of claims. The program allows qualified providers and suppliers to request a specific payment amount from their assigned Medicare Administrative Contractor (“MAC”).  Historically, processing time for a request of an accelerated/advance payment ranged between three to four weeks.

With the disruption to the healthcare industry caused by COVID-19, many providers have been unable to perform non-essential surgeries and procedures, and some providers and suppliers have been forced to lay off or furlough staff. CMS has taken steps to ensure that the accelerated/advance payment program is more readily available to providers and suppliers in order to accelerate cash flow. Most providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three-month period.

The criteria for a provider or supplier to qualify for accelerated/advance payments is as follows:

  1.  The provider or supplier must have billed Medicare for claims within 180 days immediately prior to the date of signature on the request form;
  2.  the provider or supplier must not be in bankruptcy;
  3.  the provider or supplier must not be under active medical review or any investigation in connection with program integrity; and
  4.  the provider or supplier must not have any outstanding delinquent Medicare overpayments.

Processing times for requests have been reduced to between four to six days, on average. CMS has already received over 25,000 requests from health care providers and suppliers for accelerated/advance payments. These payments serve as a loan that providers and suppliers must pay back. Beginning 120 days after disbursement of the accelerated/advance payments, CMS will apply any payments for newly submitted claims to offset the outstanding accelerated/advance payment balance.

Certain hospitals may be granted up to one year from the date of the accelerated/advance payment to repay the balance. All other Medicare Part A and B providers and suppliers shall have 210 days from the date of the accelerated/advance payment to complete the repayments. Any unpaid balance may be subject to an extended repayment plan, under which the balance shall accrue interest, currently set at the rate of 10.25%.

The request forms for the program can be found on each MAC’s website. Providers and suppliers should contact the MAC in their service area.

For more information, please call our office at 941.748.0100 or email health care attorney Alexander John at ajohn@blalockwalters.com.

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