The Centers for Medicare and Medicaid Services (“CMS”) is working with participating provides and suppliers to ensure they have the funds necessary to continue operating without disruption. During the current public health emergency caused by the COVID-19 pandemic, the Medicare Accelerated and Advanced Payment Program (the “Program”) will lend most providers or suppliers as much as 100% of the amount it received during the preceding six (6) month period. (A critical access hospital may request as much as 125% of the amount it received in the preceding 6 months.) NOTE: This discussion is limited to the Program’s impact on physicians and other Part B suppliers.
Who is eligible?
A physician’s practice or other Part B supplier that participates in the Medicare program, that-
- has submitted claims to the Medicare program within the 180-day period preceding the submission of the request for Advanced Payment; and
is not in bankruptcy; and
is not under active medical review or program integrity investigation; and
does not any outstanding Medicare overpayments.
How much can a physician or other Part B supplier request from the Program?
Physicians and other Part B suppliers may request as much as 100% of the Medicare payment amount for a three-month period.
How long does an applicant have to wait until it receives payment?
CMS has instructed the Medicare Administrative Contractors (“MAC”), such as Blue Cross of Florida, to make payment within seven days after receiving a request.
When does repayment begin?
Physicians and other Part B suppliers must begin repaying the Program within 120 days after the payment is issued.
Physicians, other Part B suppliers have 210 days from the date of the payment to repay the loan, i.e., 90 days following the date they begin making repayment.
What happens if a physician practice or other Part B supplier does not repay the Program?
Physicians, other Part B suppliers can continue to submit claims and receive payment during the initial 120-day period. However, claims submitted after the end of that period will be used to recoup the amount received by that practice under the Program.
How does a physician or other Part B supplier apply for a loan under the Program?
By submitting an applicant to its Medicare Administrative Contractor (“MAC”). For physicians and other Part B suppliers in Florida, the MAC is First Coast Service Options. Information concerning the Program can be found at www.medicare.fcso.com/coronaavirus/0460439.asp.
Written by: Stephen H. Siegel, Esq.
Stephen H. Siegel focuses his practice on assisting clients (primarily in the healthcare industry) achieve their goals while minimizing the associated business and legal risks.