The COVID-19 emergency has caused CMS (Centers for Medicare & Medicaid Services) to expand eligibility for expedited payments to Medicare providers and suppliers for the duration of the public health emergency.
Accelerated payments have been available to providers/suppliers in the past due to a disruption in claims submission or claims processing, mainly due to natural disasters. Because of the COVID-19 public health emergency, CMS has expanded the accelerated payment program to provide necessary funds to eligible providers/suppliers who submit a request to their Medicare Administrative Contractor (MAC) and meet the required qualifications.
Eligibility requirements―Providers/suppliers who:
- Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form,
- Are not in bankruptcy,
- Are not under active medical review or program integrity investigation, and
- Do not have any outstanding delinquent Medicare overpayments.
Amount of payment:
Eligible providers/suppliers will request a specific amount for an accelerated payment. Most providers can request up to 100% of the Medicare payment amount for a three-month period. Inpatient acute care hospitals and certain other hospitals can request up to 100% of the Medicare payment amount for a six-month period. Critical access hospitals (CAHs) can request up to 125% of the Medicare payment for a six-month period.
Processing time:
CMS has indicated that MACs will work to review and issue payment within seven calendar days of receiving the request.
Repayment, recoupment, and reconciliation:
The December 2020 Bipartisan-Bicameral Omnibus COVID Relief Deal revised the repayment, recoupment and reconciliation timeline on the Medicare Advanced and Accelerated Payment Program as identified below.
Hospitals repayment, recoupment and reconciliation timeline |
Original Timeline |
Time from date of payment receipt |
Recoupment & Repayment |
120 days |
No payments due |
121 - 365 days |
Medicare claims reduced by 100% |
> 365 days provider may repay any balance due or be subject to an ~9.5% interest rate |
Recoupment period ends - repayment of outstanding balance due |
Hospitals repayment, recoupment and reconciliation timeline |
Updated Timeline |
Time from date of payment receipt |
Recoupment & Repayment |
1 year |
No payments due |
11 months |
Medicare claims reduced by 25% |
6 months |
Medicare claims reduced by 50% |
> 29 months provider may repay any balance due or be subject to an 4% interest rate |
Recoupment period ends - repayment of outstanding balance due |
Non-hospitals repayment, recoupment and reconciliation timeline |
Original Timeline |
Time from date of payment receipt |
Recoupment & Repayment |
120 days |
No payments due |
121 - 210 days |
Medicare claims reduced by 100% |
> 210 days provider may repay any balance due or be subject to an ~9.5% interest rate |
Recoupment period ends - repayment of outstanding balance due |
Non-hospitals repayment, recoupment and reconciliation timeline |
Updated Timeline |
Time from date of payment receipt |
Recoupment & Repayment |
1 year |
No payments due |
11 months |
Medicare claims reduced by 25% |
6 months |
Medicare claims reduced by 50% |
> 29 months provider may repay any balance due or be subject to an 4% interest rate |
Recoupment period ends - outstanding balance due |
Application:
The MAC for Jurisdiction 6 and Jurisdiction K is NGS (National Government Services). The NGS application for accelerated payment can be found here.
The NGS Hotline telephone number is 1.888.802.3898. Per NGSMedicare.com, representatives are available Monday through Friday during regular business hours.
The MAC will review the application to ensure the eligibility requirements are met. The provider/supplier will be notified of approval or denial by mail or email. If the request is approved, the MAC will issue the accelerated payment within seven calendar days from the request.
Tips for filing the Request for Accelerated/Advance Payment:
The key to determining whether a provider should apply under Part A or Part B is the Medicare Identification number. For hospitals, the majority of funding would originate under Part A based on the CMS Certification Number (CCN) also known as the Provider Transaction Access Number (PTAN). As an example, Maine hospitals have CCN / PTAN numbers that use the following numbering convention "20-XXXX". Part B requests would originate when the provider differs from this convention. In short, everything reported on a cost report or Provider Statistical and Reimbursement report (PS&R) would fall under Part A for the purpose of this funding.
When funding is approved, the requested amount is compared to a database with amounts calculated by Medicare and provides funding at the lessor of the two amounts. The current form allows the provider to request the maximum payment amount as calculated by CMS or a lesser specified amount.
A representative from National Government Services indicated the preference was to receive one request for Part A per hospital. The form provides for attachment of a listing of multiple PTAN and NPI numbers that fall under the organization.
Interest after recoupment period:
On Monday, April 6, 2020, the American Hospital Association (AHA) wrote a letter to the Department of Health and Human Services and CMS requesting the interest rate applied to the repayment of the accelerated/advanced payments be waived or substantially reduced. AHA received clarification from CMS that any remaining balance at the end of the recoupment period is subject to interest. Currently that interest rate is set at 10.25% or the “prevailing rate set by the Treasury Department”. Without relief from CMS, interest will accrue as of the 31st day after the hospital has received a demand letter for the repayment of the remaining balance. The hospital does have 30 days to pay the balance without incurring interest.
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If you have questions or need more information about your specific situation, please contact the hospital consulting team. We’re here to help.