COVID-19 Accelerated and Advance Payments (CAAP) Recoupment and Netting Hierarchy

On October 1, 2020, Congress enacted the Continuing Appropriations Act, 2021 and Other Extensions Act, which set forth favorable terms for repayment of accelerated and advance payments issued to providers and suppliers, as defined by Social Security Act §1861 (u) and (d) respectively, during the COVID-19 PHE. Under the terms set forth in the Act, providers and suppliers will begin repaying their CAAP disbursements beginning one year from the date on which the payment was issued. After the one year delay, the Centers for Medicare & Medicaid Services (CMS) will collect these repayments through recoupment, by offsetting Medicare claims payments otherwise owed to providers and suppliers at a rate of 25% for 11 months and at a rate of 50% during the subsequent 6 month period. The netting will process at a TIN level for associated/related providers and suppliers in the same MAC jurisdiction.

            Last Updated Thu, 01 Apr 2021 20:00:23 +0000