CARES Act: Expansion of the Accelerated Payment Program: A Needed Lifeline for Medicare Providers

CLIENT ALERT

By Andrew Eills

April 2, 2020

Medicare providers are likely feeling the financial hardships caused by lower volumes, cessation of non-elective procedures, and possible staff shortages due to the novel coronavirus (COVID-19).  To increase cash flow for health care providers, the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act and subsequent guidance from CMS offers relief through specific accelerated or advance payments to hospitals, doctors, durable medical equipment suppliers, and other Medicare Part A and Part B providers and suppliers.

Accelerated Medicare payments generally are provided during natural disasters that disrupt claims submission and/or claims processing.  Congress has recognized that the pandemic is akin to a natural disaster. Section 3719 in Title III of the CARES Act expands the existing Medicare accelerated payment program for the duration of the Covid-19 emergency period.

To qualify for the accelerated and advanced payments, eligible Medicare providers must: (1) have billed Medicare for claims within 180 days prior to submission of the provider’s or supplier’s request, (2) not be in bankruptcy, (3) not be under active medical review or a program integrity investigation, and (4) not have any outstanding delinquent Medicare overpayments.

Each MAC’s website has a form for providers to use in submitting requests for these accelerated payments.  For New England (Jurisdiction K), the MAC is National Government Services (NGS). NGS’s toll free number is (855) 247-8428, and a link to its website for the request form for advanced payment is here.

Most providers and suppliers are able to request up to 100 percent of the Medicare payment for a 3-month period.  For inpatient acute care hospitals, the request can be up to 100 percent for a 6-month period. Critical access hospitals can request up to 125 percent for a 6-month period. The advanced payment is based on a calculation of net reimbursement by unbilled discharges or unpaid bills.

Recoupment of the accelerated payment commences 120 days after the issuance of the payment. Hospitals, including CAHs, have one year from this 120-day period to repay the balance of the accelerated payment. All other Medicare Part A and Part B suppliers have 210 days from the date of the accelerated payment to repay the balance During the 120-day period, providers and suppliers will continue to receive full payment for claims submitted. After 120 days, and in lieu of payment, the balance owed for a provider’s or supplier’s outstanding accelerated payment automatically will be reduced by the claim payment amount.

Medicare providers of all sizes – and not just hospitals – may wish to use this program to cover cash flow obligations during the COVID-19 crisis.