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Health Law Scan

Legal Insights and Perspectives for the Healthcare Industry

Not to be confused with the $100 billion in Provider Relief Funds established as grants to healthcare providers through the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Congress also broadened the access to the Medicare Accelerated/Advanced Payment Program (AAPP) as a tool to address financial concerns associated with reduced cash flow during the pandemic. Previously, the AAPP was only available to providers facing significant cash flow problems due to unusual circumstances, but the CARES Act removed such qualifying language during the national emergency period. While it bears with it the burden of repayment, the AAPP may be an option for certain providers unable to meet the terms and conditions of the Provider Relief Fund or that are otherwise ineligible/unable to participate.

In an earlier LawFlash, Morgan Lewis partner Scott Memmott provided a detailed overview of the AAPP program, including eligibility, amount, recoupment, and repayment. See CARES Act Offers Short-term Financial Relief for Medicare Providers/Suppliers for more details on these elements. To participate in this funding mechanism, providers are directed to make application to their respective Medicare Administrative Contractors (MACs). Links to MAC AAPP resources and forms are furnished below, and the forms vary slightly depending on the MAC, though the key elements highlighted in the LawFlash are evident. Providers that have weighed the elements of the AAPP and its repayment obligations should contact their MACs for additional details regarding the documentation and terms of the advanced payments.

Below are links to MAC webpages with information and application forms for the AAPP: