Offset Percentage Increase for COVID-19 Accelerated or Advanced Payment Refunds
On March 28, 2020, in response to the COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) made available a temporary loan program, accelerated payments to requesting providers (Part A), and advance payments to requesting suppliers (Part B), including physicians and nonphysician practitioners. COVID-19 Accelerated or Advance Payments (CAAPs) are not grants, and providers requesting and receiving CAAP payments are required to pay back the funds as determined by CMS.
CAAP refers specifically to accelerated or advance payments issued to requesting providers and suppliers as a result of the COVID-19 Public Health Emergency. The Continuing Appropriations Act, 2021 and Other Extensions Act specifies the timeline, recoupment percentages, and interest rate that CMS must use to recover CAAPs.
Following one year from the date a CAAP was issued, CMS will recover at 25% over an 11-month period, then recovery will go to 50% over a six-month period. CAAP recoupment rates will end 29 months from the date CMS first issued a CAAP to a provider or supplier. After this time, the CAAP recoupment will collect at 100%, plus interest. In addition, CMS will recoup CAAP amounts from providers and suppliers that share a TIN consistent with its authority under section 1866(j)(6) of the Social Security Act.
As providers with a remaining CAAP balance reach the end of the first 11 months of their 25 percent CAAP recoupment, depending on the date your CAAP was issued, will begin having their recoupment increased to 50 percent over the next six-month period. Providers are encouraged to alert all staff within their practice, facility, or supplier group of this change; This includes other Medicare providers that share the same tax ID number with your organization.
Frequently Asked Questions
Question: How do you know when the offset percentage will increase for you?
Answer: Identify the date your CAAP was issued. Offset began one year from that date and continues for 11 months. At the end of the 11th month, the CAAP offset recoupment percentage increases to 50 percent for all Medicare providers that share your tax ID number.
Question: How can I determine how much CAAP I still owe?
- Palmetto GBA sends our quarterly letters and email notifying providers of their outstanding balance. The last quarterly letter was sent on January 18 and the next quarterly letter is scheduled to be sent out April 18, with quarterly letters continuing to be sent out into 2023 to those providers with outstanding balances.
- CAAP balances are available for all lines of business including JJ Part A/B, JM Part A/B, and RRB through the Palmetto GBA eServices portal.
- To access this data, enter the “CVD” AR Transaction number
- The portal will display real-time status of the CAAP balance
- Access to CAAP data is limited to your PTAN/NPI combination
Question: Can I pay back my CAAP early?
Answer: An outstanding CAAP balance can be paid off by eCheck (through the Palmetto GBA eServices portal) or with a hard copy check sent to Palmetto GBA. Payments must be received in the Palmetto GBA corporate mailroom 10 business days prior to the date the offset percentage increase takes place to prevent future offsets from occurring.
- When refunding via eCheck, once logged into the Palmetto GBA eServices portal, complete your entry as follows.
- When refunding by paper check
- Access hardcopy form
- Select Forms> Finance/Overpayments then select “Non-MSP Voluntary Refund Overpayment (Check Enclosed)” form to reconcile an overpayment
- Indicate “COVID-19 Accelerated/Advance Payment Repayment” on check or in the documentation submitted with the paper check
- Please note the “CVD” AR Transaction Number(s) being repaid in your submitted documentation
- Submit all to the address at the bottom of the form