COVID-19 Accelerated/Advance Payment (AAP) Repayment FAQ

The following FAQ were created to help providers understand the process and options of repaying accelerated/advance payments (AAPs) issued for COVID-19.

As of April 26, 2020, CMS no longer accepts new applications for the Advance Payment Program (Part B providers) and CMS has announced, as of October 8, 2020, that they will no longer accept applications for the Accelerated Payments Program (Part A providers) as they relate to the COVID-19 Public Health Emergency.

The recently enacted "Continuing Appropriations Act, 2021 and Other Extensions Act," amending the repayment terms for the Expanded Accelerated and Advance Payments (AAP) Program. Accordingly, repayment of any AAP will now begin one (1) year from the issuance date of the AAP. No action is necessary from providers. This repayment process will begin automatically. The repayment terms as amended by Congress can be found in the Palmetto GBA Repayment of Coronavirus Accelerated and Advance Payments article.

* Please note that the information in these FAQ is subject to change due to CMS direction for the Public Health Emergency.

1. Question: What is the repayment plan for AAPs?

Answer: All providers may submit a voluntary refund of the AAP at any time (see FAQ 4 for how to voluntary refund). Automatic repayment will begin one (1) year after the issuance of the AAP in the form of payment offset. A payment offset is a withholding of overpayment amounts on future Medicare payments. See question 9 below for more repayment details.

Updated 10/13/2020.

2. Question: Will Medicare add interest to the recoupment for the AAPs?

Answer: If you are unable to repay the total amount of the accelerated or advance payment through recoupment within twenty-nine (29) months, you will receive a demand letter requiring repayment of any outstanding balance, subject to an interest rate of four (4) percent.

Updated 10/13/2020.

3. Question: What is the interest rate that will be charged?

Answer: If interest is accrued, it will subject to an interest rate of four (4) percent.

Updated 10/13/2020.

4. Question: Can I repay in a lump sum?

Answer: Palmetto GBA offers several options to repay an AAP. We highly recommend using eServices, through the eCheck function. This option is secure, fast and easy. However, you may still submit a hardcopy form. You will need to access the hardcopy form, which is titled “Voluntary Refund Overpayment — Check Enclosed.” You will access the form on the Palmetto GBA website under Forms/Tools, then Finance/Overpayments. Please indicate “COVID-19 Accelerated/Advance Payment Repayment” on the check or in the documentation submitted with the paper check. Do not complete any patient and claim information section on the hardcopy form.

To use eServices, and if you are a provider administrator, you may access the eCheck sub-tab under Financial Tools, entitled “Financial Forms.” If you are a provider user, you must be granted permission to the Financial Tools tab by your provider administrator. The form is dynamic and contains edits to ensure that the information needed to process the payment is entered. Please make the below selections on the form to avoid the required entry of patient/claim information.

Do you have an overpayment demand?

 
The eCheck function allows payments to be sent electronically to Palmetto GBA. By using the eCheck option and selecting the option within the eCheck form indicating the payment is not associated with a demand letter, voluntary refunds can be submitted. There is no transaction fee for submitting an eCheck payment. In the form, please upload a document stating the payment is related to repaying of an AAP.

For more information, please review the Financial Tools Section in the
eServices User Manual (PDF, 8.21 MB).

5. Question: Will I receive an overpayment demand letter before offsets occur?

Answer: No demand letter will be sent prior to recoupment starting one (1) year after the date the AAP was issued. If you are unable to repay the total amount of the accelerated or advance payment through recoupment within twenty-nine (29) months, you will receive a demand letter requiring repayment of any outstanding balance, subject to an interest rate of four (4) percent.

Updated 10/13/2020

6. Question: How will offset amounts appear on my Medicare Remittance Advice?

Answer:

Home Health, Hospice and Part A Facilities

  • Any amount offset and applied to the accelerated payment refund amount will appear on the Remittance Advice summary page in the section labeled “Withhold From Payments,” then “Accelerated Payments.” That amount will then be deducted from the “Payments” section.

Part B Providers

  • Any amount offset and applied to the refund of the advanced payment will appear on the last page of the Remittance Advice with WO indicating the amount withheld with a CVDXXX reference number.

7. Question: When does offset occur?

Answer: Offset of the AAP will begin one (1) year after the date the AAP was issued. Providers should make note of the date their refund is due based on the date their AAP was issued and plan accordingly.

Updated 10/13/2020

8. Question: What happens if I want to send a full refund in instead of allowing the amount to offset and my full refund doesn’t reach Palmetto GBA before offset begins?

Answer: Once Palmetto GBA receives and applies the lumpsum refund amount, Palmetto GBA will refund any amount collected over the AAP amounts providing there are no other outstanding overpayments that the money must be applied to.

Providers can avoid this by planning accordingly for their refund to reach Palmetto GBA in enough time for the refund to be worked and applied to the AAP refund amount before the start date of offset.

9. Question: Will my entire Medicare payment be taken in offset?

Answer:
 

  1. During the first eleven (11) months after repayment begins, repayment will occur through an automatic recoupment of twenty-five (25) percent of Medicare payments otherwise owed to the provider.

  2. During the succeeding six (6) months, repayment will occur through an automatic recoupment of fifty (50) percent of Medicare payments otherwise owed to the provider.

Once offset begins, future payments will be offset as indicated above until the AAP amount has been refunded. Recoupment of payments can also be made from "affiliated providers." An affiliated provider is a provider that shares the same Tax Identification Number (TIN) and/or is noted as part of a Hospital Group (i.e., sub-units). On the Electronic Remittance Advice (ERA), a code of "OA" is used for Part A Affiliated Withholdings and a code of "OB" is used for Part B Affiliated Withholdings. The affiliated withholding amount is reported in the total withhold of the payment recap section on the Standard Paper Remittance (SPR).

Updated 10/13/2020

10. Question: I requested and received two AAPs at two different times that total the full amount we were entitled to. When do I have to start paying the total amount back?

Answer: Current instructions indicate each payment would have a different due date. Repayment will begin one (1) year after the date each AAP was issued.

Updated 10/13/2020

11. Question: Should I hold my claims once offset begins so that my Medicare payments are not offset?

Answer: Palmetto GBA does not recommend providers take this action as it may cause interest to accrue.

12. Question: Do providers have the option to submit a Request for Extended Repayment Schedule (ERS)?

Answer: If a provider unable to repay the total amount of the AAP through recoupment within twenty-nine (29) months, the provider will receive a demand letter requiring repayment of any outstanding balance. After the demand letter is issued, an ERS option will be available to the provider.