ACG Updated Guidance: Economic Relief for GI Practices
From ACG Board Trustee Caroll Koscheski, MD, FACG

In last week’s update on economic relief for GI practices, I briefly discussed the Medicare Accelerated and Advanced Payments Program. Unlike the small business loan programs administered through the Small Business Administration (SBA), this program is strictly administered through the Centers for Medicare and Medicaid Services (CMS). The basic premise is that you present a 3-month estimate of your typical earnings based on historic information. Medicare will pay you this sum in advance. Your practice then pays off the sum owed to CMS over a period of time. 

This week, CMS announced that the agency approved approximately $34 billion for providers in one week. CMS updated this amount to over $51 billion. According to CMS, processing times are roughly 4-6 days. In a little over a week, CMS has already approved over 21,000 of the 32,000 requests it received from providers and suppliers. Prior to COVID-19, CMS had approved just over 100 total requests in the past 5 years, with most being tied to natural disasters such as hurricanes. 

The premise is to calculate your typical Medicare reimbursement over a 3-month timespan and provide this as an immediate lump sum payment to your practice. This applies to Medicare Parts A and B and will include ASC facility fees, infusion fees, and pathology. You will continue to bill Medicare as always, and be reimbursed for services provided. After 120 days, Medicare will start recouping its costs. There is a 90-day timespan on recoupments that will be interest-free. Money owed beyond that 90 days will have interest added to the amount. You may repay the remaining amount in a lump sum at any time. 

How Can You Apply? 

You are eligible if you have submitted Medicare claims over the preceding 180 days from your request. You must not be in bankruptcy and must not be under an active medical/integrity investigation. You are also ineligible if you have outstanding delinquent Medicare overpayments. 

The application form is obtained from your regional Medicare Administrative Contractor (MAC). Click here to find your local MAC. CMS has provided some guidance, as well as instructions, on how to apply for this program. Click here to read the CMS guidance.  

My Experience  

Palmetto GBA is the MAC for North Carolina and provided a simplified form on their website. My application was five simple questions. I also had the option of the MAC calculating the amount of my award as opposed to me providing data. You use your Medicare provider transaction access number (PTAN), along with your national provider identifier (NPI) and your group’s tax identification number (TIN).   
The bottom line is that you are shifting the lack of Medicare reimbursement from the current time frame to a timeframe that begins 120 days out. Please note that these payments are not forgiven at any point, unlike the SBA loan programs. One strategy you may want to consider is applying for the Paycheck Protection Program and get that approval. Click here for ACG’s guidance. If you are still coming up with severe cash flow problems, you can apply for participation in the Medicare Accelerated and Advanced Payment Program. The portion that you do not need from the Medicare award can then be paid back once your cash flow is back to operational levels. Every practice situation will be different, however, so you will need to get feedback from your accountants and your management team in making this decision.  
Stay safe,