On March 27, President Donald Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The CARES Act establishes the $100 billion Public Health and Social Services Emergency Fund (Fund) to reimburse eligible healthcare providers for expenses or lost revenue attributable to COVID-19. In recognition of the need for hospitals, especially those in rural areas, to maintain stable cash flow in order to maintain workforce and supplies, and to generally continue to operate during this time, the CARES Act expands the existing Medicare Accelerated and Advance Payments Program (APP) by allowing qualifying providers and suppliers to request advanced lump sum or periodic payments. As a result, the Centers for Medicare & Medicaid Services (CMS) announced on March 30 the mechanism for requesting the APP payments. For the duration of the COVID-19 public health emergency, a broader group of Medicare Part A providers and Part B suppliers may request APP payments.

Q: What are APP Payments?

A: APP payments are expedited payments intended to increase cash flow to healthcare providers and suppliers when there is a disruption in claims submission or claims processing. APP payments may also be offered during national emergencies, such as the COVID-19 public health emergency.

Q: Who can request to participate in the APP during this period?

A: CMS has authorized APP payments for any provider or supplier meeting all of the following criteria:

• Has billed Medicare for claims within 180 days prior to the provider’s/supplier’s signature on the request form.
• Is not in bankruptcy.
• Is not under active medical review or a program integrity investigation.
• Does not have any outstanding delinquent Medicare overpayments.

Q: If I am eligible, how much can I request?

A: Most providers and suppliers may request 100% of the Medicare payment amount for three months. Inpatient acute care hospitals, children’s hospitals and certain cancer hospitals can request 100% of Medicare payment for six months. Critical Access Hospitals (CAH) can request up to 125% of their Medicare payment for a six-month period. Providers and suppliers will need to request the authorized amount by filling out an APP request form; the form is provided on each Medicare Administrative Contractors website. Find your MAC here.  Or consult the CMS Fact Sheet which lists each MAC and the toll-free COVID-19 Hotline Hours of Operation for each MAC, for questions about what amount you can request.

Q: When will I receive my APP payment?

A: APP payments will be issued within seven (7) calendar days from the MAC’s receipt of an appropriate request.

Q: When will I be required to repay APP payments?

A: The repayment period for these payments has been extended to 120 days after the date the payment is issued. After 120 days, acute care hospitals, children’s hospitals, certain cancer hospitals and CAHs will have up to one (1) year from the date the APP payment was issued to repay the balance. All other APP recipients will have 210 days from the date the APP payment was issued to repay the balance.

Q: Do I have to pay the amount back in full after 120 days?

A: No. During the 120-day deferral period, APP recipients may submit claims and receive full payment for their claims. After the 120-day deferral period, CMS will begin to recoup the APP payment. This recoupment will occur automatically when the provider or supplier submits a claim to Medicare, and the APP recipient’s outstanding APP balance will be reduced by the claim payment amount. After the repayment period is over, each MAC will perform a manual check to ensure all APP balances have been repaid, at which time any outstanding balance will be requested as a direct payment to the MAC.

• Note, for Part A providers who receive Periodic Interim Payments, the APP reconciliation process will occur during the final cost report process.

Q: Where can I find additional information on requesting to participate in the APP?

A: The CMS Fact Sheet includes a comprehensive step-by-step guide to completing the APP request form. The form must be signed by an authorized representative of the provider/supplier, and the forms may be submitted electronically or by fax or mail.

Q: Will a request to participate in the APP affect any other financial assistance a provider or supplier could request from the Fund?

A: CMS has not specifically addressed this. However, as APP payments must be repaid, accessing the APP should not negatively impact a provider’s/supplier’s ability to access any other financial assistance through the Fund.

Authorship Credit: Katy Appleby and Charlene McGinty