CMS ACCELERATED AND ADVANCE PAYMENTS PROGRAM

On April 26, the Centers for Medicare & Medicaid Services (CMS) announced that it is reevaluating the amounts that will be paid under its Accelerated Payment Program and suspending its Advance Payment Program effective immediately. The agency made this announcement following the successful payment of over $100 billion to health care providers.

Since expanding the AAP programs on March 28, 2020, CMS approved almost 24,000 applications advancing $40.4 billion in payments to doctors. 

Beginning April 27, 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 historical direct payments made available through the Department of Health & Human Services’ (HHS) Provider Relief Fund.

Significant additional funding will continue to be available to health care providers through other programs such as the CARES Act, the Paycheck Protection Program and Health Care Enhancement Act. HHS is distributing this money through the Provider Relief Fund, and these payments do not need to be repaid.

To qualify for advance/accelerated payments the provider must: 

• Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form, 
• Not be in bankruptcy, 
• Not be under active medical review or program integrity investigation, and 
• Not have any outstanding delinquent Medicare overpayments. 

Qualified providers will be asked to request a specific amount using an Accelerated or Advance Payment Request form provided on each MAC’s website. Most providers will be able to request up to 100% of the Medicare payment amount for a three-month period.

Each MAC will work to review and issue payments within seven (7) calendar days of receiving the request.

CMS has extended the repayment of these accelerated/advance payments to begin 120 days after the date of issuance of the payment. Part A providers and Part B suppliers will have 210 days from the date of the accelerated or advance payment was made to repay the balance. The payments will be recovered according to the process described in number 7 below.  

The provider can continue to submit claims as usual after the issuance of the accelerated or advance payment; however, recoupment will not begin for 120 days. 

• Providers/ suppliers will receive full payments for their claims during the 120-day delay period. 
• At the end of the 120-day period, the recoupment process will begin and every claim submitted by the provider/supplier will be offset from the new claims to repay the accelerated/advanced payment. Thus, instead of receiving payment for newly submitted claims, the provider’s/supplier’s outstanding accelerated/advance payment balance is reduced by the claim payment amount. 
• This process is automatic. 

A step by step application guide can be found below. More information on this process will also be available on your MAC’s website.      

1. Complete and submit a request form – Forms vary by contractor and can be found on each individual MAC’s website (find your MAC here). Then complete an Accelerated/Advance Payment Request form and submit it to your servicing MAC via mail or email. 

2. What to include in the request form – Incomplete forms cannot be reviewed or processed, so it is vital that all required information is included with the initial submission. The provider/supplier must complete the entire form, including the following: 

• Provider/supplier identification information including: (i) Legal Business Name/ Legal Name; (ii) Correspondence Address; (iii) National Provider Identifier (NPI); (iv) Other information as required by the MAC. 
• Amount requested based on your need: i. Most providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three-month period. 
• Reason for request: Check box 2 (“Delay in provider/supplier billing process of an isolated temporary nature beyond the provider’s/supplier’s normal billing cycle and not attributable to other third party payers or private patients.”); and State that the request is for an accelerated/advance payment due to the COVID19 pandemic. 

3. Sign the form – The form must be signed by an authorized representative of the provider.

4. Submit the Form – Electronic submission will significantly reduce the processing time, but requests can be submitted to the appropriate MAC by fax, email, or mail. 

1. What review does the MAC perform? – Requests for accelerated/advance payments will be reviewed by the provider or supplier’s servicing MAC. The MAC will perform a validation of the following eligibility criteria:

• Has billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s or supplier’s request form, 
• Is not in bankruptcy, 
• Is not under active medical review or program integrity investigation, 
• Does not have any outstanding delinquent Medicare overpayments. 

2. When should you expect payment? – The MAC will notify the provider as to whether the request is approved or denied via email or mail (based on  preference). If the request is approved, the payment will be issued by the MAC within 7 calendar days from the request. 

3. When will the provider be required to begin repayment? – Providers will begin repayment 120 calendar days after payment is issued.

4. Do provider have any appeal rights? – Providers do not have administrative appeal rights related to these payments. However, administrative appeal rights would apply to the extent CMS issued overpayment determinations to recover any unpaid balances on accelerated or advance payments