As providers continue to deal with cash flow interruptions in the wake of the largest-ever cyberattack on the U.S. health care system, the U.S. Centers for Medicare & Medicaid Services has stepped in to offer some temporary relief. In a program announced March 9, CMS outlined how qualified providers could receive accelerated or advance payments that would be repaid by way of automatic deductions from future claims.

The program was launched in response to a Feb. 21 hack of Change Healthcare, a UnitedHealth Group subsidiary that manages multiple electronic data interchange systems including claims processing, billing, and payment. The resultant shutdown of Change systems has interrupted provider payment and made it difficult for patients to access care.

CMS Program Tied to 2023 Payment Amounts

Known as the Change Healthcare/Optum Payment Disruption program, or CHOPD, the plan offers accelerated payments to Medicare Part A providers and advance payment to Medicare Part B providers. In both instances, the amounts would reflect up to 30 days' worth of payments, with the exact amount on based on a formula — the total claims paid between Aug. 1 and Oct. 31, 2023, divided by three.

After receiving the CHOPD payment from CMS, providers would repay through Medicare claims recoupment for 90 days, with a final payoff for any remaining amounts due on day 91.

Providers Must Qualify for the CHOPD Program

Providers must meet specific criteria to receive the CHOPD funds and can find a complete list of requirements on the CHOPD fact sheet. All requests for CHOPD payments must be submitted to Medicare Administrative Contractors, or MACs, which have been required to provide information on how to request an accelerated or advance payment. A CMS webpage lists all MACs.

Requirements include:

• Inability to submit claims to receive payments from Medicare.
• Disruption in claims payment due to a business relationship with a provider that uses Change Healthcare.
• Inability to obtain sufficient funding from other sources to cover the disruption.
• Having no intention to cease business operations, not being insolvent, and, if in bankruptcy, alerting CMS.
• Having no knowledge of being under investigation for suspicious activity.
• Enrollment in the Medicare program with no delinquent Medicare debts or being on hold for a Medicare payment.
• Commitment to using the funds for operations for which they were requested.
• Agreement to all CHOPD terms.

CHOPD Doesn't Apply to MA, Medicaid; HHS Urges Commercial Payers to Act

In the fact sheet, CMS notes that Medicare Advantage Organizations are not included in the CHOPD program and urges Medicaid managed care plans to adopt some form of prospective payment program.

The U.S. Department of Health and Human Services has also issued statements encouraging the private sector to help provide relief to providers and patients. Suggestions include interim insurance company payments, reductions in administrative burden, acceptance of paper claims, and a pause to prior authorizations.

APTA encourages members to work with payers to see if prospective payments are available. Contact advocacy@apta.org for additional guidance.