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CMS Offers Financial Relief for Medicare Providers During COVID-19 Crisis

Breanne M. Rubin
4/2/20

medical professionals discussing   The COVID-19 crisis is expected to have a major impact on health care providers’ cash flow. While some providers are experiencing a much higher than normal patient volume, other providers have substantially reduced their patient volumes due to stay-at-home orders and the limitation on what some classify as “non-essential” health care services. In order to increase cash flow to healthcare providers and suppliers impacted by the COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) has expanded its current Accelerated and Advance Payment Program to a broader group of Medicare Part A providers and Part B suppliers. CMS is offering participating Medicare providers and suppliers the opportunity to take an advancement on their “typical” Medicare payments to help with cash flow shortfalls during the pendency of the public health emergency. 

   For background, CMS currently has an accelerated payment policy, the Accelerated and Advance Payment Program, for extraordinary circumstances that allows certain providers to receive an advance on Medicare payments if they have experienced financial difficulties due to a delay in payments or in other exceptional situations. 

Eligibility

   To qualify for advance/accelerated 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 Medicare Administrative Contractor’s (MAC) 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 (CAHs) can request up to 125% of their payment amount for a six-month period. 

How to Request Payment

   Eligible providers/suppliers must complete and submit an Accelerated/Advance Payment Request form. Accelerated/Advance Payment Request forms vary by contractor and can be found on each individual MAC’s website. The CGS request form can be found here.  

   In addition to providing the provider/supplier identification information, the provider/supplier will need to specify on the request form the amount requested based on the provider/supplier’s need (see “Amount of Payment” section above). Further, the provider/supplier will need to specify the reason for the request. CMS indicates that applicants should check box two (“Delay in provider/supplier billing process ….”) and specify the request is due to the COVID-19 pandemic. The form must be signed by an authorized representative of the provider/supplier. 

   Requests can be submitted to the appropriate MAC by fax, email or mail. Providers/suppliers are encouraged to submit their request form electronically to reduce processing time. 

Processing Time 

   Each MAC will work to review and issue payments within seven  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 CAHs 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.

   After the one year or 210-day period, as applicable, the MAC will perform a manual check to determine if there is a balance remaining. If there is a balance, the MAC will send a request for repayment of the remaining balance, which is collected by direct payment.

Recoupment and Reconciliation

   After the issuance of the accelerated or advance payment, the provider/supplier can continue to submit claims as usual. Providers/suppliers will receive full payments for claims submitted during this 120-day delay period. At 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/advanced payment. Therefore, instead of receiving payment for newly submitted claims, the provider’s/supplier’s outstanding accelerated/advance payment balance will be reduced by the claim payment amount. This is an automatic process. 

   During this 120-day time period, providers/suppliers can continue to file and be reimbursed for appropriate Medicare claims. The repayment/offset will not begin until 120 days after the advanced payment issuance date. However, once the 120-day time period commences, all Medicare payments will be offset at 100% of the check amount until the advanced payment is repaid. 

   For the small subset of Part A providers who receive Period Interim Payments (PIP), the accelerated payment reconciliation process will happen at the final cost report process (180 days after the fiscal year closes). 

  For additional information, please see the press release and fact sheet issued by CMS. 

  Should you have any questions concerning the Accelerated and Advance Payment Program, please contact Ms. Rubin. 

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Disclaimers:

At the date of publication the above information was correct.  It is quite possible the information above has changed as COVID-19 is a rapidly evolving situation. 

The article in this publication has been prepared by Eastman & Smith Ltd. for informational purposes only and should not be considered legal advice. This information is not intended to create, and receipt of it does not constitute, an attorney/client relationship.