The Centers for Medicare & Medicaid Services’ (CMS) accelerated payment program provides necessary funds when there are disruptions in claims submission and/or processing. The Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116–136) expanded the program to include not only acute care hospitals, but also children’s hospitals, certain cancer hospitals, and critical access hospitals. CMS further expanded eligibility for accelerated/advance payments during the COVID-19 public health emergency (PHE) to all Medicare providers and suppliers.

On April 1, 2021, CMS issued a notice “Repayment of COVID-19 Accelerated and Advance Payments Began on March 30, 2021” for all Medicare providers and suppliers who requested and received COVID-19 Accelerated and Advance Payments (CAAPs) from CMS due to the COVID-19 PHE. It notifies providers that CMS began recovering the CAAP payments as early as March 30, 2021 (depending upon the one-year anniversary of when a provider received their first payment). The notice also provides information on how to identify recovered payments. Some highlights from the article include:

• Accelerated payments function as a loan and must be repaid to CMS in full. The Continuing Appropriations Act, 2021 and Other Extensions Act, enacted on October 1, 2020, established new repayment terms for accelerated/advance payments. Among other provisions, the new terms include:
  • One year (from date payment was issued) before repayment begins — hospitals begin repayment as early as April 2021;
  • 25 percent withhold of Medicare claims during the first 11 months of repayment, followed by a 50 percent withhold during the subsequent six months; and
  • 4 percent interest applied to any remaining balance at the end of the repayment period.

The accelerated payments provided a critical lifeline to health systems during this PHE. The requirement to repay these funds could place health systems in financial distress while trying to recover from the pandemic. RCPA is requesting feedback from members on the impact of the accelerated payment relief plan. Please take a few minutes and respond to the following questions:

1. Are you/your organization aware of the Accelerated Payment Relief program from CMS?
2. Have you taken advantage of this?
3. Are there any issues with the repayment?
4. Have you been involved in any lobbying efforts to:
   1. Get this to better payment terms (e.g., interest rate, timing)?
   2. Move this to loan forgiveness?
5. Have you contacted any state or federal legislators? If so, whom?
6. Has your organization also received Provider Relief Funding and/or any other extraordinary CARES Act Funding?
7. If so, has this impacted your interest in pursuing action relative to the Accelerated Payment Relief?
8. Any additional comments?

Please send your responses to Melissa Dehoff by Wednesday, May 26, 2021.