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Tag: CMS

COVID-19 Accelerated Payments

CMS has expanded cash advances for most hospitals. Have you calculated your payment?
Updated 4/8/2020 from original 3/30/2020 article:
CMS stated that they will prioritize the accelerated payments for states that were hit the hardest (CA, NY and WA).
In a little over a week, CMS has already authorized $34B in accelerated payments to providers, approving over 17,000 requests so far out of 25,000 received.  Prior to COVID-19, CMS has approved only 100 total requests for accelerated payments in the past five years, with most being tied to natural disasters such as hurricanes.
Expansion of Accelerated Payments
In order to increase cash flow to providers impacted by COVID-19, CMS has expanded the current Accelerated and Advance Payment Program to a broader group of providers for the duration of the public health emergency.
Who is Eligible?
To qualify for accelerated payments, the provider/supplier must:
  • Have billed Medicare for claims within the last 180 days;
  • Not be in bankruptcy;
  • Not be under medical review or program integrity investigation; AND
  • Not have any outstanding delinquent Medicare overpayments
How Much Will You Receive?
Most hospitals may receive up to 100% of their Medicare payment for a 6-month period. CAHs may receive up to 125% over that same period. All other providers may receive up to 100% for a 3-month period of Medicare payments.
How Does the Process Work?
Providers that meet the qualifications must submit the appropriate forms as designated by each MAC on their respective websites. The MACs will review and issue payments within seven calendar days of receipt. Repayment must begin 120 days after the date of issuance of the payment, via withholding of future claim payments. Most hospitals will have one year from the date the accelerated payment was received to repay the balance.
For further information, please refer to the complete CMS guidance here.
Toyon’s Take:
Providers will need to review their individual MAC’s website in order to access the appropriate forms and procedures. Providers should also estimate their Medicare payments over the applicable period based on the most current data available, in order to verify the amount calculated by the MAC.
If you need assistance with that calculation, you may find the attached template helpful. Alternatively, if it is administratively easy for your organization to do, you may also want to consider generating a report from your hospital billing system that will show payments received over the applicable period up through March 30, 2020. It is our understanding that CMS may be requesting that the MACs generate a report of actual payments out of HIGLAS for the applicable period, which would match this data source.
Please contact Robert Howey at or 888.514.9312 with any questions or for assistance calculating your expected payment.
Toyon Associates, Inc.

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COVID-19 Medicare Cost Report Deadlines

Medicare Cost Report Filing Extensions
In case you haven’t have already heard from your MAC, we wanted to be sure you’re aware that CMS is currently authorizing a delay for filing Medicare cost reports with the following fiscal year end dates:

FYE Original Due Date New Due Date
10/31/2019 3/31/2020 6/30/2020
11/30/2019 4/30/2020 6/30/2020
12/31/2019 5/31/2020 7/31/2020
This will be a blanket extension. Providers need not send a request for this extension. For more information, you can access the PGBA notice here.
CA OSHPD Suspension of Late Filing Penalties
Related to this matter, the California Office of Statewide Health Planning and Development (OSHPD) is temporarily suspending their OSHPD late filing penalties for reports due between March 4, 2020 and May 1, 2020. This suspension period may be extended beyond May 1. For more information, you can access the OSHPD notice here.
Toyon’s Take:
Toyon will continue to stay on target for completing our clients’ cost reports in time for the original filing due date. We recommend that hospitals continue planning for an on-time filing.
Please contact Matt Beymer at 888.514.9312 or with any questions. 


Toyon Associates, Inc.

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COVID-19 UNCOMPENSATED CARE RECOGNITION SERVICES – Hospital Financial Assistance Policy Update

Hospitals should ensure Financial Assistance Policy language reflects ALL forms of charity discounts.

Hospital Patient Financial Assistance Policy
As the healthcare industry prepares for COVID-19, hospitals may experience high volumes of care to the most critically vulnerable population of underinsured and uninsured patients.  CMS only recognizes, and reimburses, for this charity if it is articulated in the hospital’s patient financial assistance policy (FAP).  Toyon recommends hospital teams verify language in the FAP to be reflective of all forms of charity discounts under Medicare definitions.  

What should generally be in an FAP as Charity
Hospital patient financial assistance policies should not only specify charity care discounts as patient financial assistance, but also self-pay discounts (not related to prompt pay) and non-covered Medicaid as forms of charity care. 

Access to Healthcare Crisis FAP Language
In preparation for what could be an extraordinary demand on the healthcare system, Toyon has crafted the FAP language below.  This is draft template language to assist our clients.  Any language adopted by a hospital should follow the hospital’s approval procedure (approved by hospital leadership / board of directors). 

An Access to Healthcare Crisis must be proclaimed by [hospital leadership / approved by the board of directors] and attached to this patient financial assistance document as an addendum.  An Access to Healthcare Crisis may be related to an emergent situation whereby state / federal regulations are modified to meet the immediate healthcare needs of the hospital’s community during the Access to Healthcare Crisis.  During an Access to Healthcare Crisis [hospital / health system name] may “flex” it’s patient financial assistance policy to meet the needs of the community in crisis.  These changes will be included in the patient financial assistance policy as included as an addendum.  Patient discounts related to an Access to Healthcare Crisis may be provided at the time of the crisis, regardless of the date of this policy (as hospital leadership may not be able to react quickly enough to update policy language in order to meet more pressing needs during the Access to Healthcare Crisis).  

Please contact Fred Fisher at 888.514.9312, with any questions. 


Toyon Associates, Inc.

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