Because of the coronavirus, many rehab therapy clinics are in dire financial straits. Appointment cancellations are spiking, cash flow is dwindling, and practices are struggling to pay employees. So, when the President signed the Coronavirus Aid, Relief, and Economic Security (CARES) Act into law on Friday, March 27, 2020, many healthcare providers were thrilled to learn it included provisions for accelerated and advance payments from Medicare.
But, while this program could provide a big dose of relief to some clinics, it’s not exactly a silver bullet. In fact, it could present challenges down the road—if you’re not prepared, that is. With that in mind, here’s everything you need to know about Medicare’s Accelerated and Advance Payment Program.
What is the Medicare Accelerated and Advance Payment Program?
This program essentially allows practices that contract with CMS (and need financial assistance) to apply for an advance Medicare payment that’s equal to or less than the total amount of Medicare payment they received during the previous three months. If CMS approves the practice’s application, then it will issue the full requested amount directly to the practice. However, if the practice does not pay CMS back within 120 days of the advance payment’s delivery, on day 121, CMS will automatically start taking 100% of all the practice’s Medicare payments until the entire amount is paid back in full.
In other words, you can request any amount of money from CMS—up to three months’ worth of Medicare payments—but you must pay it back. So, the program is less like a relief fund and more like a loan program—albeit without interest or fee accrual during the normal repayment time frame. (Learn more here.)
Who can apply?
While many practices will qualify for this payment program, CMS is loosely restricting who can access the money. In order to apply, a practice must:
- Have billed Medicare for claims within the 180-day period that occurred immediately prior to the date of the signature on the provider’s/supplier’s request form;
- Not be in bankruptcy;
- Not be under active medical review or program integrity investigation; and
- Not have any outstanding delinquent Medicare overpayments.
How much money should I request?
While most practices will be able to request up to the full three-month Medicare payment amount, it’s important to thoughtfully determine the amount that’s right for your practice. You don’t have to request the full amount and—in some cases—it might be wiser to take less. Here are some points to consider:
- You’ll receive the accelerated advance payment as a bulk, one-time payment. Then, if you haven’t paid CMS back after 120 days, you will forfeit 100% of your Medicare payments until CMS is paid in full. That means you will essentially lose all of your Medicare revenue until the loan is paid off. Your practice will need to plan for that time period—especially if Medicare is one of your primary payers.
- This program is better suited to help you get realistic prepayment on your current Medicare load than it is to act as a short-term cash flow booster. Securing some short-term funds might be tempting, but again, per-visit recoupment will begin after 120 days. So you’re essentially delaying the disruption to your cash flow.
- Even if you are continuing to see Medicare patients during this time, it might be tougher than usual to earn three months’ worth of Medicare payments. The remote and virtual care services Medicare is covering for rehab therapists during the COVID-19 response—that is, e-visits, virtual check-ins, and telephone visits—only pay 30–40% of what you’d earn for a normal office visit. It will take a significant volume of these visits to match your Medicare revenue for a “normal” 90-day period.
How can my practice apply?
The good news is that the application process is fairly straightforward. CMS provided a fact sheet with detailed instructions on how to apply for this loan—and we were able to boil it down even further. Just follow these five steps.
Step 1: Figure out whether the program is right for your practice.
There are many financial assistance programs available to healthcare practices right now. This one functions like a short-term loan: CMS is fronting the money, and you must pay it back. If you haven’t returned the full amount 120 days after you receive it, you will lose 100% of your Medicare revenue until CMS is paid in full.
Step 2: Determine how much money to request.
As I mentioned earlier, most practices will be able to request up to 100% of the total amount of Medicare revenue they earned during the three months prior to the request. But because you will have to pay back your entire lump sum, it would behoove you to pick an advance payment amount that your practice can realistically pay back in the required time frame. As noted above, the remote services that therapists can currently bill to Medicare patients (e.g., e-visits) pay a fraction of the reimbursement for a normal office visit. Additionally, consider your payer mix—and factor in your potential commercial payer revenue when making this decision.
Step 3: Look up your state’s jurisdiction.
Use this CMS document (or this CMS page) to determine which Medicare Administrative Contractor (MAC) jurisdiction your state falls under. For example, Arizona falls under jurisdiction F—although Arizona home health and hospice claims fall under jurisdiction 6. Once you know your jurisdiction, use the same resource to find your corresponding MAC.
Step 4: Fill out your jurisdiction’s specific application.
Each MAC has a slightly different application process. Use the following table to find the contact info for your MAC. Take a look at its website to find relevant application information, and be sure to carefully follow all instructions.
|Web- site||App- lication||Sub- mission Method|
|Add’l Resources and Notes|
|CGS Administrators, LLC (CGS)||15||(855) 769-9920||7:00 AM – 4:00 PM (Central)||Link||Link||Email, Fax, Mail||CGS.ERS.CORR @cgsadmin.com||Link|
|First Coast Service Options Inc. (FCSO)||N||(855) 247-8428||8:30 AM – 4:00 PM (Eastern)||Link||Link||Portal||N/A (Must be submitted through portal.)||Link|
|Novitas Solutions, Inc.||H, L||(855) 247-8428||8:30 AM – 4:00 PM (Eastern)||Link||Link||Portal||N/A (Must be submitted through portal.)||Link|
|Noridian Healthcare Solutions||E, F||(866) 575-4067||8:00 AM – 6:00 PM (Central)||Link||Link||Email, Fax, Mail||PartBAdvancePayments@noridian.com||Link|
|Palmetto GBA||J||(833) 820-6138||8:30 AM – 5:00PM (Eastern)||Link||Link **||Email||JJ.FINANCIALRELIEF@PalmettoGBA.com|
|Wisconsin Physician Services (WPS)||5, 8||(844) 209-2567||7:00 AM – 4:00 PM (Central)||Link||Link||AccAdvPymtReq@wpsic.com||Link|
|National Government Services (NGS)||6||(888) 802-3898||8:00 AM – 4:00 PM (Central)||Link||Link ***||Email||J6AdvancePaymentPartB@anthem.com or JKAdvancePaymentPartB@anthem.com||Link|
**To submit one request for multi PTAN/NPI combinations, applicants can submit a spreadsheet.
***Must submit with the formal written request signed by an authorized rep on a company letterhead.
Step 5: Submit the application to your MAC according to its instructions.
As mentioned in step four, each MAC has a slightly different application and submission process. That’s why you must check your MAC’s website to ensure you’re satisfying all pertinent requirements. If you have any questions about the application process, don’t hesitate to reach out to your MAC. That’s what it’s there for!
How quickly will I receive payment from CMS once I submit the application—and how will I get the funds?
CMS has not explicitly promised to disperse payment in any certain time frame—but some WebPT Members have reported receiving their payment as quickly as one week after submitting their application. Just keep in mind that your payment turnaround could be affected by application volume.
As for payment receipt, CMS will disperse these funds through the payment method you currently have on file (most likely an electronic funds transfer).
How will WebPT help Members secure these funds?
We may not be able to fill out your application for you, but we’re committed to giving our Members the information they need to successfully navigate through this crisis. So, be sure to check the Knowledge Base to find more WebPT-specific information.
Even though change is still happening at a breakneck pace, we must take the time to fully evaluate any decisions we make as we move through this crisis. Hopefully, this information will help you make the right choice for your practice regarding this particular payment program. Stay safe and be well!