Tag: Medicare Advance Payment Program (APP)
REPAYMENT OF ADVANCE PAYMENTS
QUESTION: We have received letters indicating when repayment of Advanced Payments will begin. Has Medicare released anything on exactly how that will work and how the remit will look? Will there be specific CARC or RARC codes used? Thanks!
MGMA REPLY:
Thanks for posting this question! Earlier this month, CMS announced the details of Medicare Accelerated & Advance Payment (AAP) recoupment, which are consistent with legislation passed by Congress in September:
“Providers were required to make payments starting in August of this year, but with this action, repayment will be delayed until one year after payment was issued. After that first year, Medicare will automatically recoup 25 percent of Medicare payments otherwise owed to the provider or supplier for eleven months. At the end of the eleven-month period, recoupment will increase to 50 percent for another six months. If the provider or supplier is unable to repay the total amount of the AAP during this time-period (a total of 29 months), CMS will issue letters requiring repayment of any outstanding balance, subject to an interest rate of four percent.”
Regarding remits, CMS indicates in its AAP FAQ, “Providers and suppliers will see the offset amount reflected on their Remittance Advice. Providers and suppliers should contact their MAC to receive current balance and payment information related to the repayment of their AAP payment.” I have not yet seen specifics around which codes will be used on the remits. However, the Agency plans to issue further information on the recoupment process at a later date, and the details of these adjustment codes may be covered in future guidance.
Please let me know if I can provide any further clarification!
Best,
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Matt Devino
Associate Director, Government Affairs MGMA
Washington DC
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AAP New Repayment Terms 10/12/2020
CMS released further information about the Medicare Accelerated and Advance Payment (AAP) program following the Continuing Resolution passage that revised the program’s repayment terms. Most notably, it appears CMS is automatically delaying recoupment for one year and will issue guidance on the recoupment process at a later date. The legislative text stated that CMS could delay payments “upon request” of the provider, and with this announcement, CMS will instead go further by automatically applying the delay to all recipients. From the announcement linked above:
Providers were required to make payments starting in August of this year, but with this action, repayment will be delayed until one year after payment was issued. After that first year, Medicare will automatically recoup 25 percent of Medicare payments otherwise owed to the provider or supplier for eleven months. At the end of the eleven-month period, recoupment will increase to 50 percent for another six months. If the provider or supplier is unable to repay the total amount of the AAP during this time-period (a total of 29 months), CMS will issue letters requiring repayment of any outstanding balance, subject to an interest rate of four percent.
Drew Voytal
Associate Director
MGMA Government Affairs
Washington, DC
Medicare Accelerated and Advance Payment Program (APP)
From: Drew Voytal
Associate Director
MGMA Government Affairs
Washington, DC
President Trump signed a continuing resolution appropriations bill into law that funds the federal government through December 11, 2020; section 2501 also includes several improvements to the Medicare Accelerated and Advance Payment Program (APP), including relaxing repayment terms. Upon request of a hospital or group practice that received accelerated or advance payments under Medicare Part A or Part B, CMS can:
- Delay recoupment of payments until one year from the issuance of the advanced payments;
- Once recoupment begins, apply a graduated recoupment schedule, where 25% of Medicare payments would be withheld during the first 11 months of recoupment, and 50% of Medicare payments would be withheld during the following six months; and
- Extend the period during which recipients must fully repay the advance payment amount in full to 29 months from the date of the first payment.
- The bill also lowers the interest rate on outstanding balances remaining after the 29-month repayment period from 10.25% to 4%.
CMS has not yet published information for groups wishing to avail themselves of these benefits, but we anticipate the agency will provide further information on how to make such a request. We will notify members once we see something.
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