October 5, 2020 UPDATE: As a result of a continuing resolution passed by Congress in late September which extended government funding through December 11th, 2020, the Medicare Accelerated and Advanced Payment Program (AAP) has undergone important modifications. These modifications include alterations to the previous loan repayment terms surrounding advanced Medicare payments:
- All funds are now due 365 days after disbursement of the advance payment, rather than 120 days;
- Practices now have until September 2022 for all claims submitted to offset the advance payment received, instead of the previous due date of 210 days after disbursement, then the remainder of the balance will be due;
- Reduces the per-claim recoupment amount from 100% to 25% for the first 11 months and then 50% of claims withheld for an additional six months; and
- For loans not fully repaid by the extended due date of September 2022, the interest rate will decrease from 10.25% to 4%.
April 26, 2020 UPDATE: As of April 26, 2020 CMS will not be accepting any new applications for the Advance Payment Program, and CMS will be reevaluating all pending and new applications for Accelerated Payments in light of direct payments made available through HHS’s Provider Relief Fund. For more information on the CARES Act Provider Relief Fund, you can read HQI’s blog, or visit hhs.gov/providerrelief.
Original Post: In response to the 2019 Novel Coronavirus (COVID-19) pandemic, CMS has expanded the Accelerated and Advance Payment Program to include most physicians and group practices that bill Medicare. Accelerated/advance payments are expedited payments during national emergencies to accelerate cash flow to health care providers and suppliers when there is a disruption in claims submission and/or processing.
To qualify, providers must have billed Medicare for claims within 180 days of the request, not be in bankruptcy, not be under active medical review or program integrity investigation, and not have any outstanding delinquent Medicare overpayments.
Qualified providers may request up to 100% of the Medicare payment amount for a three-month period. These requests must go directly through your Medicare Administrative Contractor (MAC) using their request form. Under reason for request, check the box for “Delay in provider/supplier billing process…” and state that the request is for an accelerated/advance payment due to the COVID-19 pandemic.
The MAC will then review and issue payment within seven calendar days of receiving the request.
Repayment begins 120 days after the MAC issues payment. For those first 120 days, you may continue to submit claims and will receive payments in full. At the end of this period, every new claim submitted will automatically be applied to the accelerated/advance payment balance. Providers have up to 210 days for all claims to offset the amount received and will then be expected to repay any remaining balance.
CMS does not offer specific guidance on how to determine the amount for the payment. HQI suggests performing a six month look back, taking the average for those months, then multiplying it by three. Please keep in mind that you do not have to ask for 100% of that amount, you could ask for 90% or less. You will want to consider how much you will be able to pay back, particularly if volume is lower. MACs will determine the appropriate payment based on your request and other financial factors on record and CMS directives.
The Accelerated/Advance Payment Program is a loan that must be repaid. It is different than the CARES Act provider relief fund payments, which are being distributed automatically and do not need to be repaid.
For more information, review the CMS Fact Sheet or contact Candace Mangum at cmangum@hqi.solutions or 804-287-6206. Access the Accelerated and Advance Payment Request form for Palmetto, the MAC for Virginia and South Carolina. Access the Accelerated and Advance Payment Request form for Wisconsin Physicians Service Government Health Administrators, the MAC for Kansas and Missouri.