CMS Reevaluates Accelerated Payment Program and Suspends Advance Payment 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 to Part B suppliers effective immediately. The agency made this announcement following the successful payment of over $100 billion to health care providers and suppliers through these programs and in light of the $175 billion recently appropriated for health care provider relief payments.
CMS had expanded these temporary loan programs to ensure providers and suppliers had the resources needed to combat the beginning stages of the 2019 Novel Coronavirus (COVID-19). Funding will continue to be available to hospitals and other health care providers on the front lines of the coronavirus response primarily from the Provider Relief Fund. The Accelerated and Advance Payment (AAP) Programs are typically used to give providers emergency funding and address cash flow issues for providers and suppliers when there is disruption in claims submission or claims processing, including during a public health emergency or Presidentially-declared disaster.
Since expanding the AAP programs on March 28, 2020, CMS approved over 21,000 applications totaling $59.6 billion in payments to Part A providers, which includes hospitals. For Part B suppliers, including doctors, non-physician practitioners and durable medical equipment suppliers, CMS approved almost 24,000 applications advancing $40.4 billion in payments. The AAP programs are not a grant, and providers and suppliers are typically required to pay back the funding within one year, or less, depending on provider or supplier type. Beginning today, 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 hospitals and other health care providers through other programs. Congress appropriated $100 billion in the Coronavirus Aid, Relief, and Economic Security (CARES) Act (PL 116-136) and $75 billion through the Paycheck Protection Program and Health Care Enhancement Act (PL 116-139) for health care providers. HHS is distributing this money through the Provider Relief Fund, and these payments do not need to be repaid.
The CARES Act Provider Relief Fund is being administered through HHS and has already released $30 billion to providers and is in the process of releasing an additional $20 billion, with more funding anticipated to be released soon. This funding will be used to support health care-related expenses or lost revenue attributable to the COVID-19 pandemic and to ensure uninsured Americans can get treatment for COVID-19.
For more information on the CARES Act Provider Relief Fund and how to apply, visit: hhs.gov/providerrelief.
For an updated fact sheet on the Accelerated and Advance Payment Programs, visit: www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf.
PPP Updates - April 27, 2020
On April 23, 2020, Congress approved $310 billion in additional funding for the SBA Paycheck Performance Program (PPP). The PPP received an overwhelming amount of applications when the program first began accepting applications on April 3rd and quickly reached its original lending limit in just 13 days.
If you have not yet received approval for a PPP loan, you will need to re-apply. The SBA will resume accepting PPP loan applications on Monday, April 27 at 10:30 a.m. ET from approved lenders. You are encouraged to apply for a loan through your local lending institution; more details on eligible lenders can be found here. Borrowers will need to complete the PPP Loan Application along with payroll documentation.
The U.S. Chamber of Commerce has created a guide to help U.S. businesses determine if they are eligible to receive a small business loan.
As part of its ongoing efforts to provide relief during the COVID-19 Public Health Emergency (PHE), the Centers for Medicare and Medicaid Services (CMS) has expanded the Medicare Accelerated and Advanced Payment Program to temporarily increase cash flow for impacted providers.
The program, which has been in existence for many years, is "intended to provide necessary funds when there is a disruption in claims submission and/or claims processing. 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." As part of CMS' response to the COVID-19 PHE, the Accelerated and Advance Payment Program has been expanded to include a larger number of Part A and Part B Medicare providers and time frames for issuing accelerated and advance payments have been significantly reduced from several weeks to approximately seven days.
The Accelerated and Advance Payment Program allows eligible providers to request up to three months of expected Medicare payments to be made if their business operations have been impacted by the COVID-19 PHE. In order to be eligible to participate in the program, providers must have billed Medicare within the last 180 days, cannot be in bankruptcy, cannot be under active medical review, and cannot have any delinquent Medicare overpayments. Repayment of Medicare accelerated, or advance payments will begin after 120 days of the request and all re-payment must be completed within 210 days of the request.
CMS has published a very informative fact sheet on the Medicare Accelerated and Advance Payment Program, including additional resources on how to apply for accelerated and advance payments.
The decision regarding whether to apply for Medicare accelerated and advance payments should be based on the individual needs of your practice but may be a viable option to temporarily increase cashflow during the COVID-19 PHE.
Questions regarding this issue may be directed to Joe McTernan at firstname.lastname@example.org or Devon Bernard dbernard@AOPAnet.org.
On April 9, 2020, the IRS released Notice 2020-23 which expands the relief that the IRS has previously granted with respect to deadlines. Specifically, Notice 2020-23 expands the prior deadline extension to all persons with specific payment and filing deadlines falling between April 1, 2020 and July 15, 2020.
The extended deadline is now July 15, 2020.
The payments and filings extended include the following:
In addition, Notice 2020-23 grants some taxpayers additional time to amend their 2016 tax returns to claim a refund, which normally must be amended within three years from the date of filing.
This means taxpayers that filed their 2016 income tax returns by April 15, 2017 now have until July 15, 2020 to amend their return and claim a refund of any overpayment of tax.
More information can be found here on the IRS website.
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) became effective Friday, March 27, 2020.
The CARES Act provides more than $2 trillion of economic relief to American companies, workers, governments and other individuals and entities, but imposes certain workforce retention obligations and other mandates or conditions on companies and employers who receive certain grants or loans under the Act. Procedures and guidance will be published in the near future regarding minimum eligibility requirements and procedures for applying for applicable financial aid.
The Act is broken up into six (6) primary titles, as follows:
• Title I – Keeping American Workers Paid and Employed Act (Section 1100, et seq.)
• Title II – Assistance for American Workers, Families and Businesses (Section 2100, et seq.)
• Title III – Supporting America’s Healthcare System in the Fight Against Coronavirus (Section 3100, et seq.)
• Title IV – Economic Stabilization and Assistance to Severely Distressed Sectors of the United States’ Economy (Section 4100, et seq.)
• Title V – Coronavirus Relief Funds (Section 5100, et seq.)
• Title VI – Miscellaneous Provisions (Section 6100, et seq.)
Highlights of the law are as follows:
• Provides a onetime cash payment of $1,200 to individual Americans making $75,000 or less ($150,000 for joint filers and $112,500 for head of household). This amount is altered by income and number of dependents.
• Greatly expands eligibility for unemployment benefits and provides claimants in participating states with an additional $600 per week in addition to the unemployment benefits paid by a state.
• Creates a $350 billion loan program for small businesses that incentivizes employee retention and provides for forgiveness for portions of loans spent on certain expenses.
• Allocates $500 billion for lending to state and local governments and qualifying businesses through yet to be announced programs that will be established by the Treasury Department.
• Allocates $130 billion in relief to the medical and hospital industries and extends Medicare coverage to additional Telehealth services.
Accelerated and Advance Medicare Payments Available
The Centers for Medicare & Medicaid Services (CMS) announced on Saturday, March 28 an expansion of its accelerated and advance payment program for Medicare-participating health care providers and suppliers, to ensure they have the resources needed during the COVID-19 national emergency. Accelerated and advance Medicare payments provide emergency funding and address cash flow issues based on historical payments when there is disruption in claims submission and/or claims processing.
The payments can be requested by hospitals; doctors; durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) suppliers; and others. Advance payments do not have to start being paid back for 120 days but must be repaid within 210 days.
To qualify for accelerated or advance payments, the provider or supplier must:
An informational fact sheet on the accelerated/advance payment process and how to submit a request can be found HERE.
UPDATES FROM CMS
• Signature Requirements: CMS is waiving signature and proof of delivery requirements for Part B drugs and Durable Medical Equipment when a signature cannot be obtained because of the inability to collect signatures. Suppliers should document in the medical record the appropriate date of delivery and that a signature was not able to be obtained because of COVID-19.
The U.S. Small Business Administration is offering designated states and territories low-interest federal disaster loans for working capital to small businesses suffering substantial economic injury as a result of the Coronavirus (COVID-19).