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Health Law

CMS Expands Accelerated and Advance Payment Program During COVID-19 Emergency

Following passage of the Coronavirus Aid, Relief, and Economic Security Act (P.L. 116-136), the Centers for Medicare and Medicaid Services (“CMS”) temporarily has expanded its Accelerated and Advance Payment Program to increase cash flow to more Medicare Part A (hospital and hospice) and Medicare Part B (medical insurance) healthcare providers and suppliers (“Providers”). CMS’ Accelerated and Advance Payment Program serves to advance necessary funds to Providers when there is a disruption in normal claim submission and processing, but Providers must submit a request and qualify for the program. The expanded program announced by CMS will continue through the current public health emergency.

To qualify for accelerated and/or advance payments (“AAP”), the Provider must:

  • have billed Medicare for claims in the prior 180 days;
  • not be in bankruptcy proceedings;
  • not be under medical review or program investigation; and
  • not have any outstanding delinquent Medicare overpayments.

To request AAP, the Provider should complete an AAP form (available through the Provider’s Medicare Administrative Contractor) requesting a specific amount. CMS advises that most Providers will be able to request 100% of the Medicare payment amount for three months. Requests will be reviewed and, if approved, paid within seven calendar days.

If a Provider’s request is approved and AAP is issued, reconciliation of the AAP vs. claims for actual services and/or supplies provided by most Providers will not begin until 210 days from the date of the AAP. Reconciliation will begin through offsets from new claims submitted after the 210 day period.

Additional information is available on the CMS website and through the Provider’s Medicare Administrative Contractor (Novitas Solutions, Inc. in the District of Columbia, Maryland, and Virginia).

Medicare providers may find AAP to be an additional option to obtain financial assistance during this difficult time. If you have questions about how this can be a resource to you, feel free to contact one of the attorneys in our Health Law practice.