March 31, 2020

Overview of FEMA Public Assistance Program and Application Process

The Centers for Medicare & Medicaid Services (CMS) has expanded its current Accelerated and Advance Payment Program (AAPP) in order to increase cash flow to a broader group of Medicare Part A and Part B providers and suppliers impacted by the 2019 Novel Coronavirus (COVID-19) pandemic. This program expansion, which includes changes from the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act, is one way that CMS is working to lessen the financial hardships of providers facing extraordinary challenges related to the COVID-19 pandemic.

This program is important to Medicare Part A & Part B providers and suppliers because it provides the following:

  • Immediate relief within seven days of request.
  • Most providers and suppliers able to request up to 100% of the Medicare payment amount for a three-month period and hospitals (inpatient acute care, children’s and certain cancer hospitals) extended payment for a six-month period.
  • Critical access hospitals (CAH) can request up to 125% of the Medicare payment amount for a six-month period.
  • No interest for at least 12 months with 120 day grace period before recoupment begins.
  • Administered by Medicare Administrative Contractors (MACs) with request forms available on MAC websites.

Details on the eligibility and the request process are outlined below.

I. Accelerated/Advance Payments

An accelerated/advance payment is a payment intended to provide necessary funds when there is a disruption in claims submission and/or claims processing. These expedited payments can also be offered in circumstances, such as national emergencies or natural disasters, in order to accelerate cash flow to the impacted health care providers and suppliers. CMS is authorized to provide accelerated or advance payments during the period of the public health emergency to any Medicare provider/supplier who submits a request to the appropriate MAC and meets the required qualifications.

II. Eligibility and Process

Eligibility: To qualify, Medicare providers and suppliers – including hospitals, doctors, durable medical equipment suppliers, and other Medicare Part A and Part B providers and suppliers - must:

  • Have billed Medicare for claims within 180 days immediately prior to the request for accelerated/advance payment,
  • Not be in bankruptcy,
  • Not be under active medical review or program integrity investigation, and
  • Not have any outstanding delinquent Medicare overpayments.

Amount of Payment: Qualified providers/suppliers will be asked to request a specific amount using an Accelerated or Advance Payment Request form provided on each MAC’s website.

  • Most providers and suppliers will be able to request up to 100% of the Medicare payment amount for a three-month period.
  • 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.
  • CAHs can request up to 125% of their payment amount for a six-month period.

Review/Processing of Payment: The servicing MAC will review requests and perform validations of provider eligibility. Providers/suppliers will be notified via email or mail (based on the provider’s/supplier’s preference) by the MAC as to whether requests are approved or denied. Each MAC will work to review and issue payments within seven calendar days of receiving a request.

Repayment: CMS has extended the repayment of these accelerated/advance payments to begin 120 days after the date of issuance of the payment. The repayment timeline is broken out by provider type below:

  • Inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and CAHs have up to one year from the date the accelerated payment was made to repay the balance.
  • All other 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 below.

Recoupment and Reconciliation: The provider/supplier 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 and at the end of the 120-day period, the recoupment process will begin. Instead of receiving payment for newly filed claims, the outstanding accelerated/advance payment balance will automatically be reduced by the payment amount for such newly filed claims. At the end of the repayment period (210 days for most providers/suppliers, one year for most hospitals), the MAC will determine if the provider/supplier has a remaining balance and send a request for repayment, if necessary. For the Part A providers that receive periodic interim payments, the reconciliation process will happen at the final cost report process (180 days after the fiscal year closes).

III. How to Request Accelerated or Advance Payment

Complete and submit a request form: A qualified Medicare Part A and Part B provider or supplier must submit the proper accelerated/advance payment request form to its servicing MAC via mail, fax, or email (CMS stated that electronic submission will substantially reduce processing time). Request forms vary by contractor and can be found on each individual MAC’s website. CMS has established COVID-19 hotlines at each MAC that are operational Monday – Friday to assist with accelerated payment requests. To locate the designated MAC, refer here

What to include in the request form: A complete form must be submitted to be reviewed or processed by the MAC. Required information includes:

  • Provider/supplier identification information (including legal business name, correspondence address, National Provider Identifier and other information as required by the MAC)
  • Amount requested
  • Reason for request – CMS instructs to 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 COVID-19 pandemic.
  • The form must be signed by an authorized representative of the provider/supplier.

For more details on AAPP and how to request an accelerated or advance payment, please refer to the CMS Fact Sheet.

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