Practice Management Alert

Question: Our practice secured money through the Centers for Medicare & Medicaid Services (CMS) Accelerated and Advance Payment (AAP) program. What do I need to know before CMS comes knocking asking for repayment?

New York Subscriber

Answer: Heed these four tips before you push the recoupment onto the back burner.

1. Know status: If you’re not sure exactly how much you have in COVID-related AAPs, you should find out. “CMS will be communicating with each provider and supplier in the coming weeks as to the repayment terms and amounts owed as applicable for any accelerated or advance payment issued,” the agency says in its release. If you don’t hear from CMS and its representatives, or if you have further questions about your AAP, “providers and suppliers should contact their MAC to receive current balance and payment information related to the repayment of their AAP payment,” CMS urges in its newly released Frequently Asked Questions (FAQ) set on the topic.

2. Plan cash flow: Hopefully, the extra time before recoupment commences and the phased-in takebacks will allow you to repay what you owe, notes finance expert Dave Macke with VonLehman & Co. in Fort Mitchell, Kentucky. But you should start planning your cash flow now to be able to cover the recoupments that will start next spring, he advises.

3. Track payments: “Borrowers [should] establish a system to track their Medicare claims submitted, Medicare reimbursement received, and Medicare reimbursements recouped during the 29-month recoupment period in order to reconcile the payback process,” says attorney Jennifer Russano Koltse with law firm Chapman & Cutler in Chicago. You’ll also need to ensure that your billing system has a way to handle accepting these payments and then recording the recoupments.

4. Keep options in mind: If you get to the end of the AAP recoupment process and find you can’t manage, you have one other course of action. As the 29-month process wraps up, “CMS will issue letters requiring repayment of any outstanding balance, subject to an interest rate of four percent,” the agency explains. “The letter also provides guidance on how to request an Extended Repayment Schedule (ERS) for providers and suppliers who are experiencing financial hardships.” If granted, an ERS can span up to three or even five years.

Know whether you qualify for ERS. “A provider or supplier would need to meet specified criteria related to financial ‘hardship’ or ‘extreme hardship’ under 42 C.F.R. 401.607(c)(2) in order to be eligible for an ERS,” CMS reminds in its FAQ set.

However, keep in mind this may not be the last word on how CMS will handle recoupment of AAPs, especially with the takebacks scheduled five to six months away, with different government leaders.

CMS will also soon issue more information about the AAP loans. “Continuing the pattern of payment transparency adopted in connection with COVID-19- related federal funding, CMS is required to publish certain AAP data on its website, including payment amounts broken down by borrower type and by Medicare certification number,” say attorneys Mark Cunningham, Doug Griswold, and Jed Roebuck with law firm Chambliss, Bahner & Stophel, P.C. in Chattanooga, Tennessee, in online analysis.

Resource: The four-page AAP repayment terms fact sheet is at www.cms.gov/files/document/accelerated-and-advanced-payments-fact-sheet.pdf.