If you received an accelerated or advanced payment (AAP), the Centers for Medicare and Medicaid Services (CMS) will begin recouping the outstanding balance from any payments due to you for your Medicare claims. If you recall, the repayments were set to begin on the one-year anniversary of receiving your advanced payment; for providers in the First Coast Service Options (FCSO) Medicare Audit Contractor (MAC) jurisdiction of Florida, Puerto Rico and US Virgin Islands, the first repayment begins on April 10th. There is no possibility of delaying or postponing the recoupment process as it is automatic.
Repayment Schedule
The repayment schedule is as follows:
- For the first 11 months after your one-year payment anniversary, CMS will retain 25% of each remittance amount and apply it to your AAP balance until the balance is paid.
- For the next six months after the first 11 months, CMS will retain 50% of your remittance amounts and apply it to any outstanding AAP balance until the AAP is repaid in full.
If there is any outstanding balance after the 17 months of deductions, providers will receive a demand letter from CMS, listing the outstanding AAP balance amount, which will be subject to immediate payment. If it is not paid within 30 days, four percent interest will begin to accrue.
Here is an example from FCSO of the recoupment process for a provider who received an AAP on 4/1/20:
How the recoupment will be identified on your remittance
First, each recoupment amount is based on the specified percentage (25% for the first 11 months, 50% for the next 6 months) applied to the total dollar amount of your remittance. It will not be deducted from specific beneficiary claims, so those claims payments will be shown in their entirety.
The remittance advice will show the offset from the total remittance with code “WO” for withholding offset and an A/R transaction code that begins with the letters “CVD.” This will help you identify the recoupment as being for AAP and not another reason.
CMS strongly advises providers to track their recoupments by creating a mechanism, such as a spreadsheet, with the total AAP amount, listing the deductions as payments are recouped, and “counting down” from the total balance. CMS will not send periodic letters, summarizing your outstanding balance.
The total amount due was included in a letter sent to all providers in October 2020. This letter also provided your recoupment start date and the CVD account number. If you cannot locate the letter, you can call the FCSO AAP Hotline.
Alternatives to the Recoupment Schedule
There are two alternatives for providers who wish to avoid the recoupment schedule above.
Request immediate offset. By submitting a Request for Immediate Offset form, providers may request that instead of the 25%/50% recoupment amounts listed above, CMS withholds 100% of your remittance payments until the balance is paid in full.
Immediate payment. Providers may hasten or speed up the AAP repayment by submitting a Return of Monies Voluntary Refund Form with their check for the outstanding balance. It’s important to note that a patient’s name and Medicare ID# are not applicable since the recoupment is not associated with a beneficiary, so leave that section blank. Under the reason for the claim adjustment, providers should list “17-Other – Please specify” and in the Additional Info field, list “COVID Accelerated/Advanced Payment Refund.”
Other Resources
CMS MLN: Repayment of COVID-19 Accelerated and Advance Payments Began on March 30, 2021
FCSO AAP hotline: 855-247-8428, option 1 (Jurisdiction N), then option 2 for AAP representative. Hours of operation 8:30 a.m. – 4 p.m. ET