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.