COVID-19 Relief: Accelerated/Advance Payment Program for Healthcare Providers and Suppliers

• CMS expands healthcare provider/ supplier eligibility for Accelerated and Advance Payment Program—providing emergency funding when claims submission/processing is disrupted by natural disasters/national emergencies.

• CMS approves approximately $34 billion for healthcare providers and suppliers via this Accelerated and Advance Payment Program.

• CMS has extended repayment deadlines for these emergency funds.

Overview

In an April 8, 2020 press release, the Centers for Medicare & Medicaid Services (CMS) stated that it has recently provided approximately $34 billion to healthcare providers and suppliers impacted by the COVID-19 pandemic. ¹ The funds were disbursed via the temporarily expanded Accelerated and Advance Payment Program—a program offering providers with accelerated and advanced funds when their claims submissions and/or claims processing are disrupted during natural disasters or national emergencies. ²

Specifically, the CMS has expanded the Accelerated and Advance Payment Program to include a broader group of Medicare Part A providers (including hospitals) and Medicare Part B suppliers (including doctors, non-physical practitioners, and durable medical equipment suppliers). Again, this expansion of included providers/suppliers is temporary and will only last for the duration of the COVID-19 health emergency. Furthermore, it is important to remember that, beginning 120 days after payments are issued, the payments are subject to automatic repayment through claim offsets.

Significantly, the CMS states that “Accelerated/Advance Payment Request forms vary by the contractor and can be found on each individual [Medicare Administrative Contractor’s] website.” ³ Without a single, clear form applicable to all in need, and with limited CMS guidance overall, providers and suppliers are encouraged to seek the advice of experienced legal counsel to determine whether they satisfy the program’s criteria or whether other alternatives may be available to help them.

Terms of the Accelerated and Advance Payment Program

No interest is charged on the advance payments so long as they are repaid within 210 days of disbursement, but interest rates are projected to be the current rate set by Treasury (10.25%) on extended repayment plans. ⁴

According to the CMS, it has extended the repayment of these accelerated/advance payments to begin 120 days after the date of issuance of the payment, and the timeline for repayment is based on provide time as follows:

• Inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and Critical Access Hospitals (CAH) have up to one year from the date the accelerated payment was made to repay the balance.
• 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. ⁵

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. ⁶

Requests for advance/accelerated payments must be submitted to the appropriate Medicare Administrative Contractor (MAC). You can locate your designated MAC here.

How to Apply

You will need to complete a request form to request accelerated/advance payments. The request form is located on each individual MAC’s website and will require the following information:

1. Identifying information:
2. Legal business name;
3. Address;
4. National Provider Identifier (NPI);
5. Any other information as required by the MAC.
6. Amount requested (based on need):
7. Qualified providers and suppliers can request up to 100% of the Medicare payment amount for a three-month period.
8. Children’s hospitals, qualifying cancer hospitals, or inpatient acute care hospitals may request up to 100% of the Medicare payment amount for a six-month period.
9. Critical access hospitals are permitted to request up to 125% of the Medicare payment amount for a six-month period.
10. Reason for request (requires form’s box 2 checked and statement that the request is necessary due to COVID-19 pandemic) ⁷

Because accelerated/advance payment request forms tend to vary by MAC, you will need to locate the correct form on your designated MAC’s website. You can locate your designated MAC here.

Frequently Asked Questions (FAQs)

How much can I request as an advance/accelerated payment?

It depends on what type of provider/supplier you are. Generally, qualified providers and suppliers can request up to 100% of the Medicare payment amount for a three-month period. If you are a children’s hospital, qualifying cancer hospital, or inpatient acute care hospital, you may request up to 100% of the Medicare payment amount for a six-month period. Finally, critical access hospitals are permitted to request up to 125% of the Medicare payment amount for a six-month period. See footnote ⁸.

How do I calculate my Medicare payment amounts?

The MAC will review a physician’s claims for the period of October 2019 – December 2019 to calculate the amount of Medicare payments. See footnote ⁹.

Do providers/suppliers have appeal rights?

No administrative appeal rights related to the payments exist; however, administrative appeal rights apply to the extent CMS issued overpayment determinations to recover unpaid balances.

Where can I find more information on other relief available?

You can visit our webpage dedicated to COVID-19 relief here.

If you have additional questions or concerns regarding the Accelerated and Advance Payment Program, contact Frost Law today at (410)-862-2806.