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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