Centers For Medicare And Medicaid Services Expands The Accelerated And Advance Payments Program For Participating Providers And Suppliers

April 8, 2020

 

The Centers for Medicare & Medicaid Services (“CMS”) is expanding the Accelerated and Advance Payment Program (the “AAP Program”) in response to the COVID-19 pandemic to allow all qualified participating Medicare providers, such as hospitals, doctors, durable medical equipment suppliers and other and suppliers, to receive accelerated payment of Medicare claims based upon billings in a certain historical period. Payments under the expanded AAP program will accelerate cash flow to impacted health care providers and suppliers during the period of the public health emergency.

Eligibility for AAP Program:

To qualify for accelerated payments under the AAP Program, a Medicare participating provider or supplier must:

  • Have billed Medicare within the 180 days prior to the request for payment under the AAP Program;
  • Not be in bankruptcy;
  • Not be under active medical review or program integrity investigation; and
  • Not have any outstanding delinquent Medicare overpayments.

Accelerated Payments under AAP Program:
Qualified providers and suppliers will be asked to request a specific amount on an “Accelerated or Advance Payment Request” form provided on each Medicare Administrative Contractor’s (“MAC”) website. Generally, eligible providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three (3) month period. Inpatient acute care hospitals, children’s hospitals, and cancer hospitals may request up to 100% of the Medicare payment amount for a six (6) month period. Critical access hospitals can request up to 125% of their Medicare payment amount for a six (6) month period. Generally, accelerated payments will be issued within seven (7) calendar days of the request.

Recoupment and Reconciliation of Payments:
The provider or supplier can continue to submit claims as usual after issuance of the accelerated payment but recoupment will not begin for 120 days. Providers and suppliers will receive full payments for their claims during the 120-day delay period. At the end of the 120-day period, the recoupment process will begin and every claim submitted by the provider or supplier will be offset automatically from their new claims to repay the accelerated payment received under the AAP Program.

Inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and critical access hospitals have up to one (1) year from the date the accelerated payment was made to repay the balance of payments received under the AAP program. That means one (1) year from the date the accelerated payment was made, the MACs will perform a manual check to determine if there is a balance remaining. If so, the MACs will send a request for repayment of the remaining balance, which will be collected by direct payment. All other Part A providers and Part B suppliers will have 210 days from the date the accelerated payment was made for the reconciliation process to begin.

Steps to Request an Accelerated or Advanced Payment:
Providers and suppliers can find Accelerated/Advance Payment Request forms on their individual MAC’s Website. Providers and suppliers should complete this form and submit to their MAC via mail or email.

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As this pandemic unfolds, recommendations and requirements are being updated and changing at a rapid pace.   If you need any assistance in understanding or addressing these issues, please contact the Garfunkel Wild attorney with whom you regularly work, or contact us at info@garfunkelwild.com.  

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