COVID-19 regulatory alert: CMS announces expanded Advance Payment Program to provide accelerated loans to healthcare providers
On Saturday, the Centers for Medicare & Medicaid Services (CMS) announced nationwide expansion of the existing accelerated Advance Payment Program (APP), making the program available for most Medicare physicians and group practices. The APP provides a quick mechanism for healthcare entities to obtain accelerated, interest-free cash flow. Specifically, the APP fact sheet outlines that:
- Physician practices can request an advanced payment of up to 100% of the Medicare payment amount based on a three-month lookback period. Hospitals can request up to 100% (125% for critical access hospitals) based on a six-month lookback period. The guidance does not specify how the lookback period is determined.
- Healthcare entities must make a request for an accelerated payment under the APP by submitting a form to their Medicare Administrative Contractor (MAC).
- Once requested, CMS anticipates MACs will issue payment within seven calendar days from the request.
- The criteria for applying for the APP are:
- Having billed Medicare for claims within 180 days immediately prior to the date of request;
- Not in bankruptcy;
- Not under active medical review or program integrity investigation; and
- No outstanding delinquent Medicare overpayments.
- APP payments are subject to repayment, which for most healthcare entities begins 120 days after the payment is received.
- During the 120-day period, the healthcare entity will continue to be paid like normal for claims submitted to Medicare.
- After the 120 days, the recoupment process starts and every claim submitted will be offset to repay the advanced payment.
This announcement is a step in the right direction; however, MGMA is advocating that the Administration make available funding that is not subject to repayment or recoupment. Recently passed legislation (the CARES Act) creates several financial assistance programs, including $100 billion in grants for Medicare physicians and hospitals. Although the APP fact sheet states that the APP reflects the passage of the CARES Act, which did expand the APP, this program is not part of the $100 billion in funding authorized under that law.