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Update on CARES Act Provider Relief Fund Application / Accelerated Payments Recoupment

8/27/20 – Dave Macke

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CARES Provider Relief Funds (PRF)

UPDATE: The deadline to apply for Phase 2 General Distribution Funding has been extended to September 13, 2020.

On July 20, 2020, The Department of Health and Human Services (HHS) issued a public notice about forthcoming reporting requirements for certain providers that accepted one or more payments exceeding $10,000 in the aggregate funding from the Provider Relief Fund (PRF) program. The reporting notice initially advised recipients that additional details regarding data elements would be provided by August 17, 2020. The Health Resources and Services Administration (HRSA) is continuing to refine its data elements and will provide those additional details at a date later than August 17, 2020. Providers will still be given the detailed PRF reporting instructions and a data collection template with the necessary data elements they will be asked to submit well in advance of the reporting system being made available – which is currently targeted for October 1, 2020.

Additional details can be found here.

CMS Accelerated and Advance Payments Recoupment

In late March, CMS issued payments to many providers under the Accelerated Payment program. The guidelines to qualify for an Accelerated Payment were significantly relaxed due to the cash flow crisis brought on by COVID. The payments to providers were meant to provide necessary funds during time of disruption in claims submission and / or claims processing. The application process was halted on April 26, 2020. The payments to providers are loans and must be repaid to CMS. The amounts received should have been recorded as a liability on the Balance Sheet.

Recoupment of the advance was to be made as an offset to future claims processing. As claims are processed, the provider will get a zero pay remit. The remittance advice will need to be posted to the accounts receivable system as paid and the loan balance reduced until the full amount is repaid. Providers also had the option to return the money early by writing a check and sending it back to the Medicare Administrative Contractor (MAC).

Inpatient acute hospitals, children’s hospitals, certain cancer hospitals and Critical Access Hospitals have one year from the date of the Accelerated Payment to repay the balance.

All other Part A and Part B suppliers will have 210 days from the date of receipt of the payment to repay the balance. 

For most providers, the 121st day would be early to mid-August. However, CMS has halted the recoupment process. Per information that we received from one of the MACs, the pause was confirmed and it is not known when it will start.  Providers still have the option to voluntarily repay the Accelerated Payment balance at any time. You will need to contact your MAC for specific guidance on this.

For any questions related to the CARES Act Provider Relief Fund, or healthcare reimbursement in general, contact Dave Macke, VonLehman’s reimbursement specialist, at dmacke@vlcpa.com or 800.887.0437.