Reingruber Alert: Temporary Expansion of AAP
7/23/2020 - By Claudia Reingruber, CPA, CHC
View recent information on the CARES Act and Temporary Expansion of AAP (Accelerated/Advance Payments) below!
Recoupment of CARES Act AAP begins soon, are you ready?
- CARES Act AAP recoupment at 100% of claims submitted begins automatically at 120 days after AAP was received
- For some providers, 120 days falls in early August 2020
- Recoupment period is defined by provider type:
- For certain hospitals, recoupment period is one year
- For all other providers, recoupment period is 210 days
- For PIP providers, recoupment will be accomplished on the cost report
- When recoupment period ends, remaining balance will become due
- Interest will accrue from date of demand for AAP remainder by MAC
- The current interest rate is 9.625%
If providers experience financial hardship with repayment:
- You can request recoupment at a reduced percentage
- You can request an Extended Repayment Schedule (ERS) for any unpaid amount at the end of the recoupment period, if lump sum repayment is not possible
- Note: An ERS must be requested through your MAC
Data required to support an ERS is as follows:
- Amount of the AAP due the program at the end of the recoupment period
- Number of months requested for the extended repayment
- Signed proposed amortization schedule
- First month's "good faith" payment based on amortization schedule
- If more than 11-month ERS is desired, much more data is needed!
- The requirements for an ERS request are in Pub. 100-06, Chapter 4, Section 50, which can be accessed here
Factors the MAC may evaluate when reviewing the request:
- The amount of the overpayment
- The provider's ability to pay
- Whether the overpayment presents a hardship to the provider
The Healthcare Division at Saltmarsh can help:
- Negotiate a reduced percentage of recoupment from your MAC
- Prepare an Extended Repayment Request (ERP)
- Evaluate the accuracy of the AAP balance in the MAC's Demand Letter
- Establish reasonable cash flow projections to support AAP repayment
If you have questions about your particular circumstances, please contact our team or call (800) 477-7458.
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