Medicare Allows for Advanced Payment of At Least Three Months of Payments for Part A & Part B Providers

On Saturday, March 28, the U.S. Centers for Medicare & Medicaid Services (CMS) announced an expansion of its Accelerated and Advanced Payment Program (“APP”), allowing almost all Medicare Part A and Part B providers to receive at least three months of their Medicare payments as an advanced payment within seven days, and a payback period of four to seven months. The CMS APP is an authority granted under various provider and supplier regulations (i.e. 42 CFR § 421.214 for Part B suppliers, 42 CFR § 412.116 for Part A inpatient hospitals) and is intended to provide necessary funds in circumstances such as regional emergencies to accelerate cash flow to impacted healthcare providers and suppliers. The recent CMS announcement expands APP eligibility to almost all Medicare Part A and Part B providers nationwide in line with the anticipated nationwide impacts of the COVID-19 crisis on healthcare providers.

In order to be eligible for this APP, a provider 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
  4. Not have any outstanding delinquent Medicare overpayments.

The vast majority of providers and suppliers are able to request payment up to 100% of three months of their Medicare payments, while inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals are able to request up to 100% of six months of their Medicare payments, and Critical Access Hospitals (CAH) can request up to 125% of six months of their Medicare payments.

The Process

Each provider or supplier will apply for the APP through their Medicare Administrative Contractor (MAC), many of whom have already posted relatively straightforward application forms on their websites. CMS has indicated that their goal is to provide payment to the provider or supplier within 7 days of the MAC’s receipt of the provider or supplier application.

The provider or supplier then continues to bill Medicare as usual, and continues to receive their claim-specific payments as usual for 120 days after the APP issuance. After 120 days, instead of continuing to be paid directly for the claims submitted to Medicare, the payment amounts will be held by the MAC and used to offset the advanced payment received. At 210 days after APP issuance (or one year after APP issuance for hospital providers), any remaining APP balance will be due. The MAC will send a request for repayment of any remaining APP balance, which will be then payable via direct payment.

For more information, you can view the CMS fact sheet regarding the APP at the following:

https://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf

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