On April 7, 2020, the Centers for Medicare & Medicaid Services (CMS) announced it has already delivered nearly $34 billion to healthcare providers through “the expansion of the Accelerated and Advance Payment Program to ensure providers and suppliers have the resources needed to combat the pandemic.”
CMS has streamlined the Accelerated and Advance Payment Program to Medicare Part A providers and Part B suppliers impacted by the Coronavirus pandemic. Accelerated/advance payments are intended to provide funding when there are disruptions in claims submission or processing and are offered during national emergencies and natural disasters. The payments are treated like loans and must be repaid.
Eligible providers include hospitals, doctors, non-physician practitioners and DME suppliers that have billed Medicare for claims within the 180 days immediately prior to submission of the request form. Additionally, providers must not be in bankruptcy; must not be under any Medicare audit or investigation; and must not have any outstanding delinquent Medicare overpayments.
Eligible Medicare providers and suppliers may request an advance payment in an amount up to 100% of their Medicare payment amount for a three-month period. Other providers, like inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals, may request up to 100% of their Medicare payment amount for a six-month period. While CMS has not yet given definitive guidance, it is expected that CMS will use payments made to providers during the latter part of 2019 to calculate the advance payment amount.
The streamlined program has reduced processing time to between four and six days, with most advance payments delivered within seven calendar days. Repayment (through recoupment against submitted claims) begins 120 days after the date of issuance. Most Part A and Part B providers will have 210 days from the date of payment to repay the balance; however, inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals can repay up to one year from the date of payment.
The COVID-19 pandemic and response is an evolving situation. All levels of government are engaged in the process of preparing new legislation, regulations and orders both to stem the spread of the virus and to provide relief to employers and employees. We will continue to monitor the situation and provide updates as applicable, especially as such updates affect healthcare providers and their practices.
For more updates on this topic and other legal updates related to the COVID-19 pandemic, please visit our COVID-19 Legal Resource Page by clicking here.