CMS expands accelerated and advanced payments to offer additional financial relief for providers during the COVID-19 emergency period

In a press release on March 28, 2020, the Centers for Medicare and Medicaid (CMS) announced expanded availability of financial assistance for providers through accelerated and advanced Medicare payment programs. Although these expedited payments are usually offered during natural disasters in specific locations and to specific providers, CMS is expanding the program for Medicare providers throughout the country during the COVID-19 Emergency Period.

This CMS announcement quickly followed the Coronavirus Aid, Relief, and Economic Security Act, better known as the “CARES” Act, which was signed into law on March 27, 2020. A number of provisions in this new legislation provide various forms of financial relief for providers during the COVID-19 Emergency Period, including expanding access to and scope of the accelerated Medicare payment program for hospitals.

Accelerated/advanced Medicare payments can be requested by the following:

  • Hospitals
  • Doctors
  • Durable medical equipment (DME) suppliers
  • Other Medicare Part A and Part B providers or suppliers

To qualify for these payments, a provider or 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.
  4. Not have any outstanding delinquent Medicare overpayments.

Providers and suppliers should evaluate if they are eligible for this assistance right away. Upon determining eligibility and submitting an application, providers and suppliers should request a specific payment amount using an Accelerated or Advance Payment Request form to their designated Medicare Administrative Contractor (MAC). See the various MAC forms in the list below:

According to CMS, most providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three-month period. As a result of the CARES Act, certain hospitals may request up to 100% for a six-month period, and critical access hospitals (CAHs) may request up to 125% of their payment amount for a six-month period.

Medicare will start accepting and processing providers’ payment requests immediately. CMS anticipates payments to be issued within seven days of a provider’s request.

CMS extended the repayment of these accelerated/advanced payments to begin 120 days after the date of issuance of the payment, while certain hospitals will have up to a full year to repay the balance, and all other Part A and B providers and suppliers will have 210 days from the date payment was issued for repayment.

CMS also provided an informational fact sheet on the accelerated/advance payment process and how to submit requests.

The CARES Act contains many other provisions relating to the assistance and support of healthcare providers during the COVID-19 emergency, including treatment provided through telehealth and other types of reimbursement boosts through Medicare and Medicaid plans. CMS continues to guidance for providers on an almost daily basis. McDonald Hopkins will continue to monitor guidance relating to assistance for healthcare providers during the COVID-19 emergency.

For additional information please contact the attorneys below.

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