Under the expanded Accelerated and Advance Payments (AAP) Program, the Centers for Medicare & Medicaid Services (CMS) issued payments to providers and suppliers to help ease financial strain due to a disruption in claims submission and/or claims processing related to the COVID-19 Public Health Emergency.
Recently, Congress enacted amended repayment terms for the accelerated and advance payments through the Continuing Appropriations Act, 2021 and Other Extensions Act:
Repayment will now begin one year after the date of the issuance of the payment.
During the first 11 months after repayment begins, repayment will occur through an automatic recoupment of 25 percent of Medicare payments otherwise owed to you.
During the succeeding six months, repayment will occur through an automatic recoupment of 50 percent of Medicare payments otherwise owed to you.
If you are unable to repay the total amount of the accelerated or advance payment through recoupment within 29 months, you will receive a demand letter requiring repayment of any outstanding balance, subject to an interest rate of four percent.
No action is necessary from you. The repayment process will begin automatically.
The following example helps illustrate the amended repayment terms for a provider that was issued an AAP on April 1, 2020:
We highly recommend that providers/suppliers create a way during the 29-month recoupment period to track the claims submitted, Medicare reimbursement received, and Medicare reimbursements recouped. This will help you reconcile the payments recouped toward your AAP receivable in your system as they are a part of the payback process.
We recognize that the COVID-19 Public Health Emergency continues to present challenges for Medicare providers and suppliers. Recall that the normal Medicare requirement is to recoup a debt a 100%; however, CMS understood this challenge and developed a flexible payment arrangement at 25% for the first 11 months and 50% for another six months with zero interest to ease providers’ burden during the PHE. We are unable to offer any modifications or exceptions to these repayment terms.
A letter was sent to providers in October 2020 with specific details on the recoupment. The letter has the total amount of money that needs repaid, the start date of the recoupment and a ‘CVD’ account number that applies to the AAP.
The AAP offsets will be assigned a specific Accounts Receivable (AR) number that starts with 'CVD' that will show as a withholding on your remittance advice. Keep in mind other offsets can occur on the same remittance advice that are claim related, so we encourage you to have a tracking mechanism for the AAP as well as your patient specific accounts.
Because the AAP was given as emergency funds it will not impact the way a claim processes, the withholds are not linked to patient accounts. We will recoup the amount from the finalized provider payment itself (after any other deductions are met for other withholds.) This total amount is to repay the monies advanced last year that now need to be applied by the recoupments. You will need to determine the best way for your organization to balance the previous AAP amount with each recoupment.
Yes, if a single TIN includes multiple Provider Transaction Access Numbers (PTANs) (for both PIP providers and non-PIP providers), the recoupment percentage will be offset at the TIN level. The offset will not exceed the maximum recoupment rate of 25% or 50% for the shared TIN.
Yes. Providers and suppliers that received an AAP payment can return the money via a check as long as the amount does not exceed $70M. You can use the return of monies form with a comment in the "Other" box stating it is for the AAP.
Effective October 8, 2020, MACs are no longer accepting payment request forms from providers. Any applications received on or after this date shall be declined
If all monies have not been paid at the end of the total 29-month time-frame, a demand letter will be issued with a total amount of monies still owed. Interest will begin to accrue at that time at four percent.
If you have any additional questions regarding the AAP repayment process, please contact our Hotline at 1-855-247-8428. Our hours of operation are Monday through Friday 8:30 AM – 4:00 PM ET.
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