CMS Starts COVID-related Accelerated or Advance Payment Program Recoupments

As of March 30, 2021, if, as a Medicare provider or supplier you received an accelerated or advance payment (AAP) from the Centers for Medicare and Medicaid Services (CMS), CMS will begin to recoup any outstanding balance from any payments due to you from your Medicare claims. When the recoupment starts depends on the one-year anniversary of when you received your first AAP from CMS.

As background, on October 8, 2020, CMS announced it was implementing new repayment terms for payments issued under the AAP program to providers and suppliers as a result of the COVID-19 pandemic. CMS additionally released a Fact Sheet regarding the new repayment terms and related issues. See our Client Alert on this issue for more detail.

Note, the revised payment terms have not changed. Providers and suppliers should start to prepare for the recoupment and plan for it to increase in the percentage recouped over the time periods that CMS has set forth in its revised payment terms.

For any questions relating to the Medicare AAP payments or repayment, please contact Ari Markenson (amarkenson@winston.com) or your Winston relationship attorney. View all our COVID-19 perspectives here. Contact a member of our COVID-19 Legal Task Force here.

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