National Government Services (NGS) Recap for COVID-19 Medicare Advanced and Accelerated Payments

On June 11, 2020, the Medicare Administrative Contractors (“MACs”) were given permission from CMS to resume the processing of applications and issuance of payments for requests for Accelerated Payments. Any providers and suppliers whose request has been on hold since April 26, 2020 will soon be receiving a decision. New providers are also invited to apply now as needed. Providers and suppliers should expect to receive a letter of approval or denial from the MAC within seven days of submitting their request to join the Accelerated and Advanced Payment Program.

Repayment, Recoupment, & Reconciliation

CMS has also extended the recoupment period of these funds to begin 120 days after the date of issuance and will continue for 90 days thereafter. The Mac will then send a demand letter for repayment of any remaining funds not recouped, funds which are subject to additional interest charges.

Providers and suppliers will still be allowed to submit claims as they would have done normally during the 120 days after issuance of the advanced or accelerated payments and they will continue to receive payment for those claims. However, any claims that are submitted will be offset from the new claims to repay the accelerated/advanced payment and reduce the balance of what was given to the provider or supplier. This process is automatic.

The majority of hospitals (inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and CAHs) will have up to one year from the date of the accelerated payment during recoupment to pay the entire balance. All other Part A and Part B providers and suppliers will have up to 210 days from the date of payment to pay the balance in full before interest begins to accrue. The interest rate is fully dependent on the U.S. Treasury rate which is currently 9.625%. This interest rate changes quarterly and is set to change again July 2020. Unused funds can be returned to NGS as overpayments and applied directly to the balance of the initial payment.

Providers and suppliers who are nearing their repayment deadline can request Extended Repayment Schedule (ERS) from NGS, although this extended repayment will still accrue interest at the U.S. Treasury rate.

Eligibility Requirements

A majority of qualified providers and suppliers can request up to 100% of their Medicare payment amount for a three-month period. However, inpatient acute care hospitals, children’s hospitals, and

certain cancer hospitals are able to request up to 100% of the Medicare payment amount for

a six-month period. Critical Access Hospitals (CAHs) can request up to 125% of their

payment amount for a six-month period. To qualify for advanced or accelerated payments, providers and suppliers must:

  1. Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form;
  2. Not be in bankruptcy;
  3. Not be under active medical review or program integrity investigation; and
  4. Not have any outstanding delinquent Medicare overpayments for the last 120 days.

For any questions regarding the Accelerated and Advance Payment Program and its functioning and formal requirements during the COVID-19 public health emergency, or for any organizational assistance with any other health care regulatory or operational matters, please contact Advis, or Call 708.478.7030.

Published: June 24, 2020