Health Care Alert: CMS Offers Accelerated Payments to Help Providers with COVID-19 Cash Flow Issues
By Nicole M. Thorn on March 31, 2020
In response to the changes for health care providers resulting from the COVID-19 pandemic and likely disruption in normal cash flow operations, the CMS has expanded its Accelerated and Advance Payment Program to a broader group of Medicare Part A and B providers and suppliers. With the passage of the CARES Act (Coronavirus Aid, Relief and Economic Security Act), 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.
- Eligibility: To qualify for advanced payments, providers must meet the following criteria:
- Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form,
- Not be in bankruptcy,
- Not be under active medical review or program integrity investigation, and
- Not have any outstanding delinquent Medicare overpayments.
- How to File: Check your Medicare Administrative Contractor’s (MAC’s) website for instructions. The CGS application can be found here.
- Payment Amount: Most providers will be able to request up to 100% of the Medicare payment amount for a three (3) month period, although providers will be asked to request a specific amount. Inpatient acute care hospitals can request up to a six (6) month period of Medicare payment amounts.
- Turnaround Time: MACs will attempt to review and process requests within seven (7) calendar days of their receipt of request.
- How Repayment Works: Beginning 120 days after the date providers receive their advanced payment, CMS will begin to offset then current payments from the advanced payment amount. Inpatient acute care hospitals will have up to one (1) year from the date of the advanced payment to repay the balance. All other Part A and B providers will have 210 days from the date of the advanced payment to repay the balance. For Part A providers who receive Period Interim Payments (PIP), the advanced payment will be included in the reconciliation and settlement of the final cost report. During this 120-day time period, providers 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. Once the respective repayment period has expired (either one (1) year for hospitals or 210 days for all other providers), MAC’s will send a request to the provider to repay any remaining balance still owed.
- Reason for Request: Note, when filing the application, under “Reason for Request”, be sure to check box 2 (“Delay in provider/supplier billing process…”) and provide the COVID-19 pandemic as the reason for your request.
Many providers are experiencing an unprecedented time with the COVID-19 pandemic. Some providers are experiencing a much higher than normal volume of work, while 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—essentially when your concern or risk for COVID-19 exposure seems greater than your other health care needs. That said, CMS has recognized this impact on its Medicare panel of providers and is willing to advance payments to help offset the cash flow impacts. There are several financial opportunities to help with cash flow issues and this is just one. If you would like some assistance learning about other options, please contact us. Brouse McDowell has a team of dedicated attorneys in corporate, commercial, tax and employment law in addition to our health care team. We’re here to help you triage what has become an extraordinary amount of information.