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Accelerated and Advance Payments Program for Providers and Suppliers During COVID-19 Emergency

Craneware® Insights Regulatory Updates – CWI1219 (06 April 2020)


Topic

Accelerated and Advance Payments Program for Providers and Suppliers During COVID-19 Emergency

On March 28, 2020, CMS released a CMS News article and a Fact Sheet entitled “Expansion of the Accelerated and Advance Payments Program for Providers and Suppliers During COVID-19 Emergency” in which information is provided regarding eligibility and instructions for receiving expedited Medicare payments.

Provider Types Affected

Critical Access Hospitals
OPPS Hospitals
Provider-Based FQHC
Provider-Based Rural Health Clinics
Physicians

Departments/Areas Affected

Business Office
Compliance / Revenue Integrity
Finance

What You Need to Know

On March 28, 2020, CMS posted information on the Accelerated and Advance Payment Program. This program provides emergency funding when there is a disruption in claims submission and/or claims processing and is intended to accelerate cash flow to impacted health care providers and suppliers. The expedited payments are generally offered in natural disasters, but CMS is expanding the program for all Medicare providers throughout the country during the public health emergency related to COVID-19. The expedited payment can be requested by hospitals, doctors, durable medical equipment suppliers and other Medicare Part A and Part B providers and suppliers.

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.

Payment Amount Information

An Accelerated or Advance Payment Request form will be provided on each Medicare Administrative Contractor’s (MAC) website. The eligible provider/supplier will be asked to request a specific payment amount, as follows:

  • Providers and suppliers: May request up to 100% of the Medicare payment amount for a three-month period.
  • Inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals may request up to 100% of the Medicare payment amount for a six-month period.
  • Critical access hospitals (CAHs) may request up to 125% of their payment amount for a six-month period.

Each MAC will review the  payment request forms and issue payments within seven (7) calendar days of receiving the request.

Step-by-Step Guide to Request Accelerated or Advance Payment:

  1. Complete and submit a request form, which is located on each individual MAC’s website. The form may be submitted via mail or email. If the provider/supplier needs assistance, CMS has established COVID-19 hotlines at each MAC that are operational Monday – Friday. You may contact the MAC that services your geographic area. Please refer to the Fact Sheet for a listing of MACs and geographic areas or refer to: https://www.cms.gov/Medicare/Medicare-Contracting/Medicare-Administrative-Contractors/Downloads/MACs-by-State-June-2019.pdf.

  2. Information the provider/supplier will be required to provide is as follows:
    • Provider/supplier identification information:
      • Legal Business Name/ Legal Name
      •  Correspondence Address
      •  National Provider Identifier (NPI)
      •  Other information as required by the MAC
    • Amount requested based on your need:
      • Most providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three-month period. However, inpatient acute care hospitals, children’s hospitals, and certain cancer hospitals are able to request up to 100% of the Medicare payment amount for a six-month period. Critical access hospitals (CAHs) can now request up to 125% of their payment amount for a six month period.
    • Reason for request:
      • Please check box 2 on the request form (Delay in provider/supplier billing process of an isolated temporary nature beyond the provider’s/supplier’s normal billing cycle and not attributable to other third party payers or private patients); and
      • State that the request is for an accelerated/advance payment due to the COVID19 pandemic.
  3. Signature: The form must be signed by an authorized representative of the provider/supplier.

  4. Form Submission: Requests can be submitted to the appropriate MAC by fax, email, or mail. Electronic submission will significantly reduce the processing time. The provider/supplier may also contact the MAC using the MAC hotlines (see Factsheet for Hotline telephone numbers).

  5. Form Review and Approval Process: The MACs will review requests for accelerated/advance payments and perform a validation of the above-mentioned eligibility criteria.

  6. Payment Timeline: The MAC will notify the provider/supplier of request approval or denial via email or mail (based on provider/supplier preference). The payment for approved applications will be issued by the MAC within 7 calendar days.

Repayment

Repayment will begin 120 days after the date of issuance of the payment. The timeline for the repayments is provider-specific, 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.

Recoupment and Reconciliation

The recoupment and reconciliation process will be implemented as follows:

Provider/Supplier:

  • The provider or supplier may continue to submit claims as usual after the issuance of the accelerated or advance payment.
  • Recoupment will not begin for 120 days during which time the provider or supplier will receive full payments for their claims.
  • At the end of the 120-day period, the recoupment process will begin. Every claim paid during the 120-day period will be offset from the new claims to repay the accelerated/advanced payment.

Hospitals:

  • Inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and critical access hospitals will have up to one year from the date the accelerated payment was made to repay the balance.
  • One year after issuance of the accelerated payment, the MACs will determine if there is a balance remaining, and if so, the MACs will send a request of repayment of the remaining balance, which is collected by direct payment.
  • All other Part A and Part B providers and suppliers not listed above will have up to 210 days for the reconciliation process to begin.
  • The accelerated payment reconciliation process will happen through the final cost report process (180 days after the fiscal year closes) for Part A providers who receive Period Interim Payments (PIP).

Appeal Rights

Providers/suppliers do not have administrative appeal rights related to these payments. However, administrative appeal rights would apply to the extent CMS issued overpayment determinations to recover any unpaid balances on accelerated or advance payments.

Action Needed

CMS is posting COVID-19 information on a daily basis and the content of the information remains “fluid”. The Craneware Insights articles provide an overview of the CMS information as it is presented at that time. Questions pertaining to the temporary CMS program changes should be directed to your MAC.

Providers and suppliers should review the information contained in the CMS Fact Sheet in its entirety. This information should be disseminated to the person(s) responsible for high level decision-making within the facility/office. Staff responsible for patient account payment reconciliation need to be informed of the method in which Medicare will recoup the accelerated/advanced payment in approximately 120 days after issuance of such.

Effective Date

28 March 2020

Background

Coronavirus Aid, Relief and Economic Security (CARES) Act:

https://www.congress.gov/bill/116th-congress/senate-bill/3548/text

CMS Emergencies Webpage:

https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/Current-Emergencies-page

Reference

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

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