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

What it is advisable to learn 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 further Medicare Half A suppliers and Half B suppliers in response to the COVID-19 pandemic. An accelerated or advance cost is a cost that’s designed to assist money move disruptions throughout a nationwide emergency.

According to 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 cost 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 could repay their CAAP by contacting their Medicare Administrative Contractor (MAC). If such CAAP is repaid in full, the compensation phrases famous under won’t apply.

If a CAAP just isn’t repaid in full (as detailed above) the next compensation phrases will apply:

  • The compensation course of will start routinely. Reimbursement for every CAAP will start one 12 months from the issuance date of such cost.
  • 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% through the first 11 months of compensation and 50% through the subsequent 6 months).
  • If the CAAP just isn’t paid in full after month 29, the MAC will subject a requirement letter to the supplier or provider requesting cost of the remaining stability. If cost just isn’t acquired in full inside 30 days from the date of the letter, curiosity will start accruing on the excellent stability at a price 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 just isn’t penalized however can be required to repay the complete quantity on the finish of the 29 month interval. MACs will subject letters for any excellent balanced owned as detailed above.

If experiencing monetary hardship, suppliers and suppliers are inspired to succeed in out to their MAC to request an Prolonged Reimbursement Schedule (ERS) after a requirement letter is issued. An ERS is a debt installment cost plan, which permits a supplier or provider to pay their money owed over a 3 12 months interval. In instances of utmost 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 follow group.

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