Medicare Accelerated Payment Program’s Recoupment Paused for DC and Maryland Providers

BACKGROUND

The Centers for Medicare and Medicaid’s (CMS) Accelerated Medicare Payment program provided advance payments to a significant number of hospitals and providers to minimize the affect of revenue shortfalls brought on by the COVID-19 pandemic. Shortly after announcing the “Medicare Accelerated and Advance Payment Program”, CMS stopped accepting applications from Part B providers on April 26th due to the availability of funds provided by the Provider Relief Distributions enacted by the CARES Act.

Ultimately, over $100 Billion of Advance payments were distributed to hospitals and providers. Payments made under this program are an advance on future claims of the traditional fee-for-service Medicare reimbursement. Originally, repayment was due to start in August of this year via claim reimbursement offsets/withholds. Seven Medicare Administrative Centers (MACs) across the country were tasked with administering accelerated and advance payments and taking initial actions to recoup Medicare funds at some point.

WHY IT HAS BEEN PAUSED FOR DC AND MARYLAND PROVIDERS 

In general, CMS instructs MACs on how to adhere to the agency’s guidance and regulatory requirements. Legislation being reviewed in Congress has caused some MAC’s to pause the recoupment process. According to an article published by the National Law Review on August 5th, 2020 (found here) it is likely that the recoupment period will be extended given the state of COVID-19 recovery.

Figure 1 shows the proposed extended changes within the Health Economic Recovery Omnibus Emergency Solutions (HEROES) and the Health Economic Assistance, Liability Protection and Schools (HEALS) Acts for Hospitals, Providers, and Suppliers.

Figure 1 – Proposed Recoupment and Repayment Extensions

In May 2020, the US House of Representatives passed the Health Economic Recovery Omnibus Emergency Solutions (HEROES) Act, which would extend the timeline for recoupment and repayment of the loans. On July 27, 2020, Senate Republicans introduced the Health Economic Assistance, Liability Protection and Schools (HEALS) Act, which also would extend the repayment and recoupment terms, although for a shorter period. HEROES would take additional steps of reducing the interest rate and reducing the amount of recoupment. HEALS does not include parallel proposals affecting interest rates or recoupment amounts.

 

WHAT SHOULD I DO?

We spoke with Novitas Solutions, the MAC for Providers in DC, DE, MD, NJ & PA, who have decided to delay the recoupment process until they have received further guidance from CMS. By allowing a brief grace period that accounts for the activity on Capitol Hill, Novitas hopes to gain greater clarity on behalf of their beneficiaries and in turn a smoother recoupment process.

If you are a provider in Novitas’ J/L Jurisdiction (DC, DE, MD, NJ or PA) and have additional questions, contact Novitas Solutions at 855-247-8428. Press option 2 to select jurisdiction J/L, then select option 2 and stay on the line to speak to a representative about accelerated or advance payments.

HOW CAN WE HELP?

We are monitoring this matter very closely. As always, if you have any immediate questions about how these new provisions will impact your practice, please contact Maureen West McCarthy, or your current KatzAbosch representative.

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