CMS expands Accelerated and Advance Payment Program for Medicare

Over the weekend, the Centers for Medicare & Medicaid Services (CMS) announced the expansion of its Accelerated and Advance Payment Program for Medicare providers and suppliers during the COVID-19 public health emergency. The expansion includes changes from the recently passed CARES Act.

The Accelerated and Advance Payment Program provides expedited Medicare payments to participating providers and suppliers when there is a disruption in claims processing or claims submission. Advance payments are often offered during national emergencies or natural disasters to assist impacted health care providers and suppliers.

 

 

“In this situation, CMS is expanding the program for all Medicare providers throughout the country during the public health emergency related to COVID-19. The payments can be requested by hospitals, doctors, durable medical equipment suppliers and other Medicare Part A and Part B providers and suppliers,” reads the statement from CMS.

According to CMS’s fact sheet on the program expansion, health care entities do not need to meet specific COVID-related criteria in order to qualify for the advanced payments. They simply need to have billed Medicare for claims within the past 180 days, not be in bankruptcy, not be under active medical review, and not have outstanding delinquent Medicare overpayments.

Providers and suppliers must request a specific amount in their advanced payment requests to Medicare Administrative Contractors (MAC). Most hospitals can request up to 100% of the Medicare payment amount for a six-month period; critical access hospitals can request up to 125% of their payment amount. Other Medicare providers and suppliers including physician practices, skilled nursing facilities, home health aides, and ambulatory surgery centers can request up to 100% of the payment amount for a three-month period.

CMS estimates MACs will issue payments within 7 days of the provider’s request.

“Access to advanced payments could provide a significant financial relief to many health care entities that have had to delay/cancel many non-emergency procedures,” says Hall Render attorney David Snow. “Although CMS anticipates MACs making payments within 7 days of a request, the sooner the request is submitted, the more likely they are to get payment consistent with that timeframe.”

Repayments for these advance payments will begin 120 days after the date of issuance. Most hospitals will have up to one year to repay the balance. All other Part A providers and Part B suppliers will have 210 days to repay.

“The Accelerated and Advance Payment Program provides a fast way for affected Medicare health care providers and suppliers to obtain accelerated cash flow that is interest free for at least one year for hospitals and 210 days for other providers and suppliers. There appears to be little downside to requesting the advance payment and could be of particular benefit to entities facing cash-flow concerns,” says Hall Render attorney Benjamin Fee.

Attorneys at Hall Render note that these advance payments are not part of the $100 billion Public Health and Social Services Emergency Fund established in the CARES Act.