Starting Soon: The Demand of Remaining COVID-19 Accelerated or Advanced Payment Balances

Published 04/04/2023

In March of 2021, CMS began recouping outstanding 2019 Novel Coronavirus (COVID-19) Accelerated and Advance Payment (CAAP) balances, one year from the date on which a provider or supplier received their CAAP. Following one year from the date a CAAP was issued, CMS recovered at 25 percent over an 11-month period, then recovered at 50 percent amount over a six-month period. CAAP recoupment rates end 29 months from the date CMS first issued a CAAP to a provider or supplier. After that, CAAP recoupment will collect at 100 percent, plus interest (4 percent), through the demand process. In addition, CMS will recoup CAAP amounts from providers and suppliers that share a Tax Identification Number (TIN) consistent with its authority under section 1866(j)(6) of the Social Security Act.

Depending on when a provider’s CAAP was issued, 100 percent recoupment may begin as early as mid-September 2022, and any outstanding CAAP balances will start the demand process to recover the debt(s). Throughout the CAAP recovery process, Palmetto GBA has apprised you about your outstanding CAAP balance through the issuance of Repayment Account Statements and remittance advices referencing any CAAP amounts recouped. At the end of the 29th month, providers with outstanding CAAP amounts will receive a demand letter(s). The outstanding CAAP balance must be paid in full within 30 days of the date of this letter to avoid the assessment of interest.

Under the existing regulations at 42 CFR 405.374 and 405.375, providers and other suppliers will have 15 days from the date of this demand letter to submit a rebuttal (dispute). CMS can fully recoup overpayments 15 days from the date of this demand letter. The CAAP Debt Dispute (CDD) process grants providers and other suppliers an opportunity to dispute the accuracy of the amount listed in the demand letter. A CAAP dispute is not an appeal of the overpayment determination. Please remember CAAP repayments received on or after the issue date of the demand letter may not be reflected in the demand letter, and this should not be cause to file a dispute. Providers and other suppliers may review the most current CAAP balances using the direction below. 

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 AR Transaction number from the demand letter
    • Please note that the demand letter’s AR Transaction number is different from the quarterly Repayment Account Statements that were sent previously
  • The portal will display real-time status of the CAAP balance
  • Access to CAAP data is limited to your PTAN/NPI combination

An outstanding CAAP balance can be repaid using the preferred method, eCheck (through the Palmetto GBA eServices portal), wire transfer 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 100 percent recoupment is scheduled to begin to prevent the recoupment from occurring.

  • When refunding via eCheck, once logged into the Palmetto GBA eServices portal, complete your entry as follows. 

 Do you have an overpayment demand? Yes is selected. Did you receive an overpayment letter? No is selected.

  • When refunding by hard copy check
    • AFTER you have received a demand letter, follow the instructions provided in the demand letter.
      • Note the demand letter number and/or AR Transaction Number(s) being repaid in your submitted documentation
    • BEFORE receiving your demand letter
      • 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
      • Note the AR Transaction Number(s) being repaid in your submitted documentation
      • Submit all to the address at the bottom of the form
  • If you would like to wire your repayment, please send an email to 
    • for Jurisdiction M providers
    • for Jurisdiction J providers
      • Please be sure to include your provider number and demand letter AR Transaction Number, and a Palmetto GBA associate will reach out to you with the necessary information and instructions for completing the wire transfer.
      • Palmetto GBA prefers wire transfers to be in excess of $5 million however exceptions may be granted. Please discuss with the Palmetto GBA associate when contacting the appropriate above email addresses.

Note: If a providers or other supplier has additional outstanding overpayments, the oldest dated demand letter amounts will be recouped first.

For more information on the CAAP program, please review the CAAP Fact Sheet and Frequently Asked Questions.

You may email questions to:

Was this article helpful?