Recoupments for AAP Loans

CMS has announced that the Medicare Accelerated and Advanced payment (AAP) program has reached loan maturity. Effective immediately, physicians who took out an AAP loan in April 2020 will begin to see recoupment of those funds as Medicare claims are paid. The repayment process will be implemented based on the one-year anniversary issue date of any first AAP loan payment and will show on each Remittance Advice (RA) as an adjustment in the Provider-Level Balance section of the RA. It is important to note that HHS has firmly stated that providers cannot use Provider Relief Fund payments to repay payments made under the CMS AAP Program. Additionally:

• For the first 11 months of the repayment period, the recoupment rate will be 25% of any reimbursement for claims paid to the physician. During the last six months, the offset will be 50% of the claims due to the provider.
• After the end of the 6 month period, Medicare Administrative Contractors (MACs) will issue a demand letter for full repayment of any remaining balance. If payment is not received within 30 days, interest will accrue at the rate of 4% from the date they issue the demand letter. After that, they will assess interest for each full 30-day period that the balance due is not repaid.

The Medicare Accelerated and Advanced payment program was part of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) CMS began offering to providers during the first weeks of the COVID-19 emergency to increase cash flow for physicians impacted by the pandemic. CMS suspended this program on April 26, 2020.

If you have questions about AAP repayments, your MACs may have more information. Find their website at http://go.cms.gov/MAC-website-list.