APS - Updates on the Accelerated and Advanced Medicare Payment (AAMP) and CAREs Act, Provider Relief Fund (PRF) from HHS

APS - Updates on the Accelerated and Advanced Medicare Payment (AAMP) and CAREs Act, Provider Relief Fund (PRF) from HHS

APS continues to monitor and navigate through the daily updates involving the COVID-19 crisis and the multiple relief options available to our physicians. Our goal in this effort is to keep you informed and provide insight that we feel is both important and beneficial to know so that future decisions can made with a level of certainty and confidence. The AAMP and CAREs Act PRF relief options remain very fluid, and new information is being uncovered and shared daily.

Accelerated and Advanced Medicare Payment (AAMP): There was some critical information shared yesterday, by CMS / Medicare that we felt it was necessary to provide an immediate update. Many of our physicians have already made the decision to apply for and have already received their AAMP from Medicare. APS learned yesterday, via a CMS / Medicare web-ex, that this loan will accrue an interest penalty if not paid back in full after the recoupment period ends. The recoupment period as we know it today is as follows:

• Recoupment begins 120 days after the issuance of the AAMP (i.e., on day 121)
• Repayment in full is required after 210 days (seven months) after the date the accelerated payments are issued.
• Repayment is NOT subject to interest UNTIL the end of the repayment period (seven months)
• At the end of the repayment period, the MAC will send a demand letter if there is a remaining balance:
• Demand letter will indicate remaining balance to be paid
• Physician can then submit a direct payment to pay off balance in full
• A 30-day grace period before interest on balance begins
• Interest rate is the prevailing rate set by the Treasury, currently 10.25%
• If the physician cannot pay the balance at the end of the repayment period, the physician can contact the MAC about an extended payment plan; the extended payment plan would occur beyond the repayment period, thus interest would be applied.

As we all understood, the AAMP was / is a loan that would have to be paid back during a recoupment period. However, learning that an interest penalty is now tied to this loan gives us additional pause for concern. APS is hopeful that your volume levels will reach and or exceed past levels, but that is an unknown that no one can predict at this time. Given those uncertainties, APS encourages our physicians who have received the AAMP or are awaiting the approval and payment of the AAMP to utilize those funds out of absolute necessity since there is the possibility of paying more than what was borrowed if full recoupment of payment is not made with in the recoupment period.

CAREs Act Provider Relief Fund (PRF): This relief option is still very new and there are many unanswered questions around this fund, the biggest of which being who and what qualifies for this relief payment. As communicated by APS last week, many of our physicians have already received this unsolicited payment in their bank account, and if you haven’t, you should receive it shortly. There are significant reporting requirements and limitations to use these particular funds. APS strongly encourages you to consult both your accountant and legal counsel before using PRF monies towards your practice

Below are the links to both the Accelerated and Advanced Medicare Payment and HHS PRF programs. You will find much more detailed information surrounding both relief options via those two resources.

Accelerated and Advanced Medicare Payment fact sheet): https://www.cms.gov/files/document/Accelerated-and-Advanced-Payments-Fact-Sheet.pdf

CAREs Act Provider Relief Fund: https://www.hhs.gov/provider-relief/index.html

As always APS and your Client Service Manager are here to help you and your team navigate through these processes.

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