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Accelerated and Advance Payment Program

Recoupments have Started for the COVID-19 Accelerated/Advanced Payment

The recently enacted Continuing Appropriations Act, 2021 and Other Extensions Act amended the repayment terms for the COVID-19 accelerated/advance payments. The changes to the repayment terms are listed below:

Here’s the Revised Repayment Terms

    • The repayment period has been extended and the automatic recoupment will begin one year after the date the accelerated or advance payment was issued.
    • During the first 11 months after repayment begins, the recoupment rate will be 25% and repayment will occur through an automatic recoupment of the provider/supplier Medicare payments.
    • At the end of the 11-month period, the recoupment rate will increase from 25% to 50%. The automatic recovery at the 50% recoupment rate will continue for six months.

If the total amount of the accelerated/advance payment is not recovered within 29 months from the date the payment was made, a demand letter for the outstanding balance will be issued. The demanded amount will be subject to a 4% interest rate.

Lastly, the Accelerated and Advance Payments Program related to the COVID-19 Public Health Emergency will be reported on the remittance advice with “CVD”.

National Government Services will provide updates to you. We encourage you to check our education calendar for the latest updates. We will be scheduling sessions to assist you through this process.

Key Points on Recoupment Amounts

    • COVID-19 ARs are last: Regular Medicare AR debts will be netted prior to any COVID-19 ARs. This includes any ARs created after the COVID-19 ARs are created. This includes ERS monthly payments. Normal offsets will occur first, then COVID ARs will net.
      • For example, the provider is scheduled to receive a payment of $100 on their RA. They have an ERS set up for $50. COVID-19 recoupment will be 25% of the $100 RA amount “owed” to provider. Therefore, the COVID-19 recoupment amount will be $25, and the final net payment for the RA will be $25.
    • One provider receives multiple COVID-19 AAPs: If one PTAN received two COVID-19 AAPs, 12.5% will be applied to the recoupment for each AAP and the total offset will be 25% of scheduled payment amount for the RA
      • For example, the provider received two COVID-19 AAPs, one on 3/31 and one on 4/30. The recoupment will be 25% for each RA from 3/31-4/29 to be applied to the first AAP. On 4/30, they will now have two COVID-19 ARs on their RAs. Both will be 12.5%.
        • The percentage is split by the number of AAPs. Therefore, if there were four AAPs for one PTAN, the four COVID-19 ARs will be 6.25% on each RA (totaling 25%).
    • Affiliated providers: Any/each related provider (same Tax ID) to the PTAN that received the AAP will each offset 25% of the total RA amount. Any affiliate PTANs will offset 25% of their remaining amount on their RA after any regular AR or ERS offsets are made. CMS is looking at the Tax ID to get the recoupment from the advanced payment regardless of which PTAN actually received the payment. More information on affiliated provider recoupment is available on our website within the Overpayments tab Nettings/Offsets Across Organization Affiliations.

Frequently Asked Questions

  1. Will NGS recoup the entire AAP amount all at once?  

Answer: No, recoupment begins 12 months after the date the accelerated or advance payment was issued. During the first 11 months after repayment begins, repayment will occur through an automatic recoupment of 25% of Medicare payments otherwise owed to the provider. During the succeeding six months, repayment will occur through an automatic recoupment of 50% of Medicare payments otherwise owed to the provider. If the provider is unable to repay the total amount of the accelerated or advance payment through recoupment within 29 months (12 months (time from AAP issued to start of recoupment) + 11 months (25% repayment period) + 6 months (50% recoupment period)), they will receive a demand letter requiring repayment of any outstanding balance, subject to an interest rate of 4%.

  1. We cannot afford to pay this back what do we do?

Answer: At this time, the recoupment is automatic and there is nothing that can be done to stop the process.  

  1. Why did it take so long to start the takebacks?

Answer: Due to the COVID-19 pandemic continuing and providers having concerns with recoupment, CMS delayed the recoupment process for 12 months from the date the AAP was issued.

  1. When did I get the accelerated payment/how can I get confirmation that I received this accelerated payment?

Answer: The early notice letter you received provides the date that the recoupment will begin. You can review the remittance statements that were around one year prior to the date on the letter. For example, if the letter states recoupment will begin on 3/31/2021, then you received the payment around 3/31/2020. You can also review your bank statements and/or work with your accounting department.

  1. How much do we owe in total for the AAP?

Answer: The early notice letter shows the balance of the AAP amount still owed at the time of the letter. If you made voluntary repayments since the date of the letter, you will deduct the voluntary repayment(s) from the amount on the letter to determine the amount owed.

You can also view the AAP balance through NGSConnex. This information is available in the Financial section by selecting “Outstanding Overpayments”. From here, you can export the overpayments to excel using the Export button. You will then see a list of each individual (actual) AR in an excel format. You can view the AAP balance by locating the AR(s) that start with “CVD”.

  1. Did we get a letter? 

Answer: If you have an outstanding balance for an AAP, you received a letter. This letter was sent out in October 2020.

  1. What if we already paid back the AAP amount in full? 

Answer: If you no longer have a balance owed to Medicare for the AAP, you will not be part of the recoupment process as you no longer have an outstanding balance.

If you have questions about the Accelerated and Advance Payment Program, you may call the NGS Hotline at 888-802-3898 for assistance. Representatives are available Monday through Friday for JK providers from 8:00 a.m.–4:00 p.m. ET and for J6 providers from 8:00 a.m.–4:00 p.m. CT.

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