April 2, 2021

The Centers for Medicare and Medicaid Services (CMS) released a Medicare Learning Network (MLN) article on April 1 concerning the Advanced and Accelerated Payment Program (AAPP). As our readers will recall, this was one of several programs the federal government made available to medical providers who were facing financial difficulty due to the public health emergency (PHE). Those choosing to avail themselves of these emergency disbursements were essentially taking out a loan. Those loans have now become due.

According to the April 1 MLN article, Medicare has begun recouping AAPP payments from providers who requested and received these funds. The actual beginning of the recoupment process will commence one year after the provider’s first AAPP payment installment. That means that some providers began having their payments recovered as early as March 30 of this year.

If you partook of the AAPP, here is what you can expect now that loans have become due:

Repayment begins one year starting from the date you were issued your first payment.
Beginning one year from the date your funds were issued, and continuing for 11 months thereafter, CMS will recover the AAPP funds from Medicare payments due to providers at a rate of 25 percent.
After the end of this 11-month period, CMS will continue to recover remaining AAPP funds from Medicare payments due to providers at a rate of 50 percent for six months.
After the end of the six-month period, your Medicare Administrative Contractor (MAC) will issue you a demand letter for full repayment of any remaining balance of the AAPP funds. If they don’t receive payment within 30 days, interest will accrue at the rate of four percent from the date your MAC issues you the demand letter. After that, they will assess interest for each full 30-day period that you fail to repay the balance.
Please make sure that you are aware of, and prepared for, these recoupment provisions. Again, this only applies to those who received Advanced or Accelerated Payment Program funds. For more information on this topic, please visit the following link and then click on the MLN article: https://www.cms.gov/outreach-and-educationoutreachffsprovpartprogprovider-partnership-email-archive/2021-04-01-mlnc#_Toc68168159.