Date: April 3, 2020Attorney: Mohamed H. Nabulsi

April 3, 2020
By Mohamed H. Nabulsi

Under the recently enacted Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, the Centers for Medicare & Medicaid Services (“CMS”) is currently making interest-free advances (“Advances”) to eligible Medicare providers that would be later recovered from prospective reimbursements payable to such providers.

To qualify for Advances, the Medicare provider/supplier must:

  1. Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form;
  2. Not be in bankruptcy;
  3. Not be under active medical review or program integrity investigation; and
  4. Not have any outstanding delinquent Medicare overpayments.

Eligible Medicare-participating physicians will be able to request an Advance on their fees in the amount of up to 100% of their Medicare payments for a three-month period. Once the request is submitted to Medicare Administrative Contractor (“MAC”), MAC will generally review the request and issue a payment within seven (7) days thereafter.

Advances are subject to repayment obligations.  Repayment begins 120 days after the Advance has been issued.  During the initial 120 days, providers can continue to submit claims and will be reimbursed for such claims in the usual course of business.  After the initial 120 days have elapsed, the recoupment process will begin, and every claim submitted thereafter will be offset to repay the Advance.  Accordingly, instead of receiving payments for the new claims, the Advance balance will be automatically offset by the claim payment amount.  Medicare-participating physicians will have 210 days from the issuance of the Advance to repay the balance.

MACs are currently accepting and processing Advance request forms. For additional information please refer to the CMS Fact Sheet on Accelerated and Advance Payment Program. Should you have any questions about the Accelerated and Advance Payment Program or require assistance with the Advance request form, do not hesitate to contact us.