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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.

Visit our COVID-19 RESOURCE HUB for ongoing updates and information. Due to the ever-changing nature of this event, you should always consult a professional.


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