Hurt by the Cyberattack on Change Healthcare? Here Are Your Options

What You Need to Know

Because of Change Healthcare's size, the cyberattack has led to significant cash flow problems for many providers and suppliers due to disruptions in claim submissions and payments. In response, CMS announced late last week that it would offer accelerated payments for Part A providers and advance payments for Part B suppliers. These measures aim to provide financial support to those unable to submit claims or receive Medicare payments due to the incident. We will walk you through the mechanics of the program first, and how you apply for accelerated/advance payments second.

How it Works

The program offers you payments equivalent to the value of up to 30 days of Medicare claims. CMS calculates this based on the monthly average of claims paid to you between August 1, 2023, and October 31, 2023. If you accept accelerated or advance payments, Medicare immediately begins recouping those amounts automatically from Medicare claims over the next 90 days. If you have any remaining balance due after 90 days, the full balance is due on day 91. You can request either the maximum allowable as calculated by CMS, or a specific amount not to exceed the maximum allowable.

How You Apply

To qualify, you must demonstrate all of the following:

• An inability to submit claims or receive payments due to your business relationship with Change Healthcare or due to a relationship that other payers you work with have with Change Healthcare
• You do not have sufficient alternative funding to cover the disruption in claims payment, processing, or submission resulting from the cyberattack;
• You intend to continue business operations and are not presently insolvent (if you are in bankruptcy, you must notify Medicare of that fact);
• You and all parent, subsidiary, or related companies must not be under any healthcare-related program integrity investigation.
• You are currently and validly enrolled in the Medicare program;
• You have no delinquent Medicare debts/are not on a Medicare payment hold or suspension; and
• You will use the funds for the operation of your organization.
  

The request for accelerated or advance payments must be made for each provider or supplier individually, using their unique NPI and Medicare ID (PTAN).

What this Means for You

If you are facing material short-term cash flow issues as a result of the Change Healthcare cyberattack and you satisfy the criteria in the bulleted list above, you can apply to Medicare for accelerated payments (Part A providers) or advance payments (Part B suppliers). These payments are designed to support your business in the immediate future, but it is important to understand that they do not constitute a loan and cannot be forgiven. You cannot later reduce the amount owed nor can you seek longer repayment timelines. If you are found to have falsified any certification or acknowledgment as part of the application process, Medicare will immediately demand the full balance from you.

You should also closely monitor communications to you from other payers that you rely upon for revenue. The Biden Administration (Dept. of Health and Human Services/Department of Labor) issued a joint statement calling on UnitedHealth Group specifically and all other insurers generally (including Medicaid plans) to consider interim/advanced payments to protect providers like you. The joint statement notes that "[l]arger payers in particular have the balance sheet stability to advance payments."

Finally, if you currently use Change Healthcare as your claims clearinghouse, CMS has streamlined the process for you to change clearinghouses.

You can click here to access the online form you need to request accelerated or advance payments.

We will keep you apprised of further developments regarding this incident as they occur.