Does your practice have pandemic-related financial hardship? If your general surgery practice has suffered money woes due to the COVID-19 pandemic, CMS might have relief for you in the form of a loan recoupment program for Medicare providers. Review: CMS began expanding its Accelerated and Advance Payment (AAP) program last spring to help fiscally challenged providers deal with COVID-19-connected, cash-flow snafus. From March 28 to April 26, CMS distributed $106 billion through the program and offered extremely tight terms for repayment at 120 days from the date loans were issued. According to a CMS fact sheet, $98 billion went to approximately 22,000 Part A providers and $8.5 billion to about 28,000 Part B providers. After April 26, CMS shut down its COVID-related AAPs because other relief funds, including the CARES Act Provider Relief Fund and Paycheck Protection Program, kicked in, notes finance expert Dave Macke with VonLehman & Co. in Fort Mitchell, Kentucky. That was a relatively short window, Macke says. Notice October AAP Extension On Oct. 8, CMS announced it would alter the repayment terms to align with Congress’ recently passed Continuing Appropriations Act, 2021 and Other Extensions Act, giving providers more time.
“In the throes of an unprecedented pandemic, providers and suppliers on the frontlines needed a lifeline to help keep them afloat,” said CMS Administrator Seema Verma in a release on the change. “CMS’ advanced payments were loans given to providers and suppliers to avoid having to close their doors and potentially causing a disruption in service for seniors. While we are seeing patients return to hospitals and doctors providing care we are not yet back to normal.” “These AAP Loans provided quick access to funds at [a] time when many … healthcare providers were facing an unexpected and unprecedented disruption in cash flow,” says attorney Jennifer Russano Koltse with law firm Chapman & Cutler in Chicago. The new AAP update aligns with the act and allows the agency to: Big news: “To allow even more flexibility in paying back the loans, the $175 billion issued in Provider Relief Funds can be used towards repayment of these Medicare loans,” CMS says in the release.
Pocket These 4 Steps to Prepare for AAP Recoupment Medicare providers have won some breathing room on AAP repayment, but they can’t just ignore things until next spring. Heed this advice to stay on top of the matter: Remember: “A provider or supplier would need to meet specified criteria related to financial ‘hardship’ or ‘extreme hardship’ under 42 C.F.R. 401.607(c)(2) in order to be eligible for an ERS,” CMS reminds in its FAQ set. Bottom line: Keep in mind this may not be the last word in how CMS will handle recoupment of AAPs, especially with the takebacks scheduled five to six months away. CMS will also soon issue more information about the AAP loans. “Continuing the pattern of payment transparency adopted in connection with COVID-19 related federal funding, CMS is required to publish certain AAPP data on its website, including payment amounts broken down by borrower type and by Medicare certification number,” note attorneys Mark Cunningham, Doug Griswold, and Jed Roebuck with law firm Chambliss, Bahner & Stophel, P.C. in Chattanooga, Tennessee, in online analysis. Resource: The four-page AAP repayment terms fact sheet is at www.cms.gov/files/document/accelerated-and-advanced-payments-fact-sheet.pdf.
If you don’t hear from CMS and its representatives, or if you have further questions about your AAP, “providers and suppliers should contact their MAC to receive current balance and payment information related to the repayment of their AAP payment,” CMS urges in its newly released Frequently Asked Question (FAQ) set on the topic.