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Volume 21.06

In 2020, the U.S. Centers for Medicare & Medicaid Services (“CMS”) expanded the availability of Accelerated and Advance Payments to Medicare providers to provide assistance with cash flow during the COVID-19 Public Health Emergency (“PHE”).

CMS has released MLN Matters Number “SE21004”, which provides information regarding the repayment of Accelerated and Advance Payments.

Repayment begins one (1) year starting from the date the provider received the advanced funds.  Beginning on the anniversary of the advance and continuing for eleven (11) months, payments to the provider will be reduced by 25% in the form of withholdings from remittances.

At the end of the eleven (11) month period, the withholding from payments will increase to 50% of payments for a period of six (6) months or until the remaining advanced funds have been recovered, whichever occurs first.  At the end of this seventeen (17) month period, any remaining balance will be demanded for repayment.  Interest on any demanded overpayments will be charged at four percent (4%) beginning thirty (30) days from the demand.

Providers are eligible to request an Extended Repayment Schedule (“ERS”) on any unpaid balances at the end of the seventeen (17) months; however, remaining balances, if any, are not generally expected to be significant in amount due to the lengthy recovery period provided and the rate of repayment through withholdings.

The repayment of advance payments is not an eligible use of Provider Relief Funds.

Providers eligible for periodic interim payment (“PIP”) reimbursement will have the repayment withholdings made directly from their normal PIP reimbursement.

Other information is available here.


Recently, the Department of Health and Human Services (“HHS”) provided updates to the PRF FAQs on certain issues.  The updates provide limited additional information; however, those responsible for the eventual submission of the use of PRF should remain aware of all changes.  Some issues discussed in the updates are:

  • The recovery of funds exceeding those reported as eligible expenses or lost revenues,
  • The allowable timeframe to calculate COVID-19 expenses or lost revenue,
  • How a parent organization may use its funds across the affiliated group of providers,
  • Cost-based reimbursement providers and the calculation of eligible expenses,
  • Further information regarding the calculation of expenses attributable to the COVID-19 PHE not reimbursed by sources other than PRF, and
  • The interaction between multiple funding sources.

See the updated FAQs here.