CMS Expands Accelerated and Advanced Health Care Payments During COVID-19

The Centers for Medicare and Medicaid (CMS) expanded the Accelerated and Advanced Payment Program to increase cash flow to health care providers, physicians, and suppliers during the COVID-19 pandemic.

Following is an overview of key program details, application tips, and factors to consider after receiving CMS payments.

Key Information

Eligible Medicare providers, physicians, and suppliers may submit Accelerated and Advanced Payment Request forms to their Medicare Administrative Contractor (MAC).

Recipient Qualifications

According to the CMS Accelerated and Advanced Payments fact sheet, the number of providers, physicians, and suppliers who qualify for these payments has expanded beyond those who have historically qualified.

Required eligibility qualifications must be met to receive payments, and MACs have established hotlines and scheduled informational calls and webcasts to assist with requests.

Payment Amounts

Initially, all qualified providers, physicians, and suppliers needed to specify the CMS funding amount they needed to receive. However, the application form now being used by MACs instead asks applicants if they need to receive the maximum amount, as calculated by CMS, or an amount that is less than the maximum.

Funds Distribution

MACs strive to review and issue payment within seven calendar days of receiving a request. These funds are an advance of Medicare payments that the recipients must repay, and the timeline varies by recipient type. However, repayments will be delayed for 120 days for all recipients.

Recoupment and Reconciliation

Within 120 days of applying for funds, providers, physicians, and suppliers will receive full payment for claims they’ve submitted. After 120 days, each claim submitted will be offset until the advance is repaid or the repayment timeline has been reached, in which case the balance will likely be due. The CMS program expansion will continue until the national emergency is deemed over.

Updated Request Forms

Request forms appear to vary by MAC, and MACs are posting and issuing revised payment request forms that should be used in future application requests. Applicants should verify that they’re applying with the latest forms, which can be found through their MAC’s website.

Application Process Tips

As of April 9, 2020, CMS has approved approximately 21,000 requests for $51 billion in payments to providers, physicians, and suppliers. However, the process hasn’t been without its hiccups.

Payment Amounts

CMS has allegedly provided payment-cap amounts for MACs to apply when processing payment requests. In some cases, there have been significant errors in the cap amounts—up to 50% of what’s due, according to the calculated amount from paid claims data over the review period.

That means it’s imperative that recipients compute from paid-claims history the amount they believe they’re due, and work with their MAC to ensure the CMS maximum amount is properly stated.

Considerations

Providers, physicians, and suppliers could likely benefit from applying for this advanced funding, but there are a few considerations applicants should review before submitting an application.

Eligibility

Providers, physicians, and suppliers should verify they qualify by reviewing the fact sheet.

Provider Numbers

Evaluate all related provider numbers for each hospital and health system—including subprovider units, home health, hospice, and provider-based rural health clinics. This can reveal if a separate application is needed to receive appropriate reimbursement on the accelerated payment.

The Amount Due

If you elect to receive the CMS maximum, the amount due should represent claims payments received during the measurement period. That equates to the following amounts based on provider type:

  • Inpatient acute care hospitals, children’s hospitals, and cancer hospitals. 100% of the Medicare payment amount for six months—ended December 31, 2019
  • Critical access hospitals. 125% of the Medicare payment amount for six months—ended December 31, 2019
  • Most other providers and suppliers. 100% of the Medicare payment amount for three months—ended December 31, 2019

Impacts on Cash Flow

These funds are an advance and will have to repaid. Providers, physicians, and suppliers should factor this into cash flow analysis for the coming months, particularly during the repayment period.

We’re Here to Help

For more information about Medicare Accelerated and Advanced Payments, application assistance, or subsequent administration, contact your Moss Adams professional.

Note on COVID-19

During this unparalleled time, we’re closely monitoring the COVID-19 situation as it evolves so we can provide up-to-date guidance and support to help you combat uncertainty. For regulatory updates, strategies to help cope with subsequent risk, and possible steps to bolster your workforce and organization, please see the following resources: