Home Health & Hospice Week

At first, home health agencies were worried that providers under the Review Choice Demonstration wouldn’t qualify, since they are under “active medical review.” But then CMS paused the program, along with almost all other kinds of medical review (see story, p. 92).

How it will work: “Qualified providers/ suppliers will be asked to request a specific amount using an Accelerated or Advance Payment Request form provided on each MAC’s website,” CMS instructs in a fact sheet about the payments. Home health and hospice agencies will be able to request up to 100 percent of the Medicare payment amount for a three-month period.

The payments are relatively short term, however. Home health and hospice agencies “will have 210 days from the date of the accelerated or advance payment was made to repay the balance.” And recoupments will start at day 120 — four months from when the MAC issues the payment.

Not left out: Accelerated payments are available for agencies on Periodic Interim Payment (PIP) too, points out consulting firm The Health Group in Morgantown, West Virginia. For PIP providers, “the accelerated payment will be included in the reconciliation and settlement of the final cost report,” CMS says in the fact sheet.

Are Accelerated Payments A No-Brainer?

A no-interest, free loan may seem like it should be automatic. But that’s not always the case, experts caution.

Pros: Agencies should “seriously consider taking advantage of the opportunity,” suggests reimbursement expert M. Aaron Little with BKD.“It’s an interest-free loan.”

Think of it as an interest-free cash advance, offers finance expert Dave Macke with VonLehman & Co. in Fort Wright, Kentucky.

Many agencies have been struggling with billing under PDGM, including submission glitches from software on both the Medicare and provider sides, notes Lynn Olson, owner of billing company Astrid Medical Services in Corpus Christi, Texas.

“For agencies with cash flow issues, this is a good idea,” Macke tells Eli.

“There is little downside to requesting the accelerated payment for any entity,” counsels law firm Hall Render in online analysis. Providers “facing immediate cash-flow challenges” should especially contemplate it.

Cons: Providers must understand “this is not money you get to keep forever,” Macke stresses.

“The APP payments are advances, not subsidies or grants,” Hall Render emphasizes.“The payments do have to be repaid to CMS.”

Providers can’t even treat it “as a loan that you have several years to pay back,” points out Melinda Gaboury with Healthcare Provider Solutions in Nashville.

Repayment will begin at day 120 with offsets to your claims being processed, Macke explains.The system will continue to offset claims until the accelerated payment amount is fully repaid by day 210. (CMS hasn’t detailed what it will do if the amount isn’t repaid by day 210, but experts predict an overpayment demand.)

Agencies should only request the payments if they fully understand the terms, Little stresses.“If an organization doesn’t feel it can sustain the recoupment process, then this may not be an opportunity they want to pursue.”

In other words: This option won’t help you if you will have the same PDGM billing problems four months from now that are delaying your reimbursement today.

You should have “legitimate reasons as to why you cannot bill and get reimbursed through the normal process,” Gaboury cautions.“Signed physician orders is the number-one reason that agencies cannot get final claims filed timely and I understand that the physicians are heavily involved in our current situation as well.”

Making this option sustainable requires calculating a realistic advance amount.HHAs may be tempted to request their payment amounts from the October-to-December period last year — especially if payments were higher than under the first quarter of PDGM in January to March of this year, Macke notes.

That may be warranted if you expect reimbursement to rebound as you figure out PDGM billing mechanics. But don’t get carried away with pie-in-the-sky bounce-back scenarios.

“Estimates of how much is needed should be founded on documented evidence that this is the amount you need to function and that the volume of billing you are going to be doing will support the money being taken back, plus your cash needs during that time,” Gaboury advises.

The accelerated payment judgment call is yours, Hall Render points out. As long as you pass the four eligibility questions, “there is no specific need-based threshold,” it says. The provider “only has to check a box stating there is a delay in billing.”

If you are on the fence on whether to request accelerated payments, you may want to just keep it in your pocket.CMS has announced no deadline, and you could make the request when you need it, Hall Render advises.v

Note: The accelerated payments fact sheet is at www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf.