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HomeHealth LawWhat it is advisable to find out about CMS’s restoration of COVID-19...

What it is advisable to find out about CMS’s restoration of COVID-19 Accelerated and Advance Funds


 

Background on Accelerated and Advance Funds

In March of 2020, CMS expanded the COVID-19 Accelerated and Advance Funds (CAAP) Program to extra Medicare Half A suppliers and Half B suppliers in response to the COVID-19 pandemic. An accelerated or advance fee is a fee that’s designed to assist money move disruptions throughout a nationwide emergency.

In keeping with the CARES Act and beneath the Persevering with Appropriations Act, 2021 and Different Extensions Act, compensation beneath the CAAP Program begins one 12 months from the date of every issued fee to a supplier or provider.

CMS announcement and compensation phrases

On April 1, 2021, CMS introduced that, starting March 30, 2021, it started recovering CAAPs acquired by Medicare suppliers and suppliers whose one 12 months compensation date is up.

A supplier or provider might repay their CAAP by contacting their Medicare Administrative Contractor (MAC). If such CAAP is repaid in full, the compensation phrases famous beneath won’t apply.

If a CAAP will not be repaid in full (as detailed above) the next compensation phrases will apply:

  • The compensation course of will start robotically. Compensation for every CAAP will start one 12 months from the issuance date of such fee.
  • As soon as repayments start, Medicare suppliers and suppliers will proceed to submit claims, however a portion of the brand new claims can be offset to repay the CAAP (25% throughout the first 11 months of compensation and 50% throughout the subsequent 6 months).
  • If the CAAP will not be paid in full after month 29, the MAC will difficulty a requirement letter to the supplier or provider requesting fee of the remaining stability. If fee will not be acquired in full inside 30 days from the date of the letter, curiosity will start accruing on the excellent stability at a charge of 4%.
  • If a supplier or provider acquired a CAAP and by no means reopened his/her supplier or provider location, then the supplier or provider will not be penalized however can be required to repay the complete quantity on the finish of the 29 month interval. MACs will difficulty letters for any excellent balanced owned as detailed above.

If experiencing monetary hardship, suppliers and suppliers are inspired to achieve out to their MAC to request an Prolonged Compensation Schedule (ERS) after a requirement letter is issued. An ERS is a debt installment fee plan, which permits a supplier or provider to pay their money owed over a 3 12 months interval. In circumstances of maximum hardship, the plan might be prolonged as much as 5 years.

Nicole Jobe and Elisabeth Volk are members of Thompson Coburn’s Well being Care apply group.

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