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CMS Offers Emergency Advanced Medicare Payment Program: What You need To Know

By Michael A. Igel & Tara M. Barton | Categories: Articles, COVID-19 task force, Health CarePrint PDF April 2020

Many health care providers are experiencing significant financial and operational disruptions during the Coronavirus Disease (“COVID-19”) pandemic. To help combat these burdens, on March 28, 2020, the Centers for Medicare and Medicaid Services (“CMS”) announced the expansion of its Accelerated and Advanced Payment Program (the “Program”). The Program was established by CMS several years ago and allows Medicare Part A and B providers and suppliers to request advanced payments for services rendered during certain emergencies. Historically, the Program has been implemented following natural disasters such as hurricanes and earthquakes. These changes will apply during the COVID-19 public health emergency.

Under the Program, a covered provider or supplier is qualified if he, she or it:

      1. Billed for claims during the 180-day period prior to the request for advanced payments,
      2. Is not in bankruptcy,
      3. Is not “under active medical review or program integrity investigation”, and
      4. Does not have “outstanding delinquent Medicare overpayments.”

Most qualified providers can receive advanced payments for up to three months’ worth of claims. The estimated amount for these payments is determined by CMS based on amounts historically received by the provider or supplier. The provider can either request to receive the maximum amount or a lesser amount of the eligible payments. Payment will be received within 7 days of the submission of approved requests.

It is important to note that providers and suppliers cannot appeal CMS’ calculation of the accelerated payment amount. In addition, since these accelerated payments are akin to an advance, providers and suppliers must repay all accelerated payments as specifically set out in CMS guidelines.

Should a qualified provider or supplier decide to request accelerated payments, the request is made through the provider or supplier’s Medicare Administrative Contractor (“MAC”). The MAC for Florida suppliers and providers is First Coast Service Options Inc. (“First Coast”), and the request form is available on First Coast’s Website.

The Johnson Pope Health Care Team is available to answer any questions you may have regarding the Program.

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