COVID-19 Accelerated/Advance Payment (AAP) Repayment FAQ

** Update**

The following FAQ were created to help providers understand the process and options of repaying accelerated/advance payments (AAPs) issued for COVID-19.

Beginning on April 26, 2020, CMS is no longer accepting any new applications for the Advance Payment Program (Part B providers), and CMS is reevaluating all pending and new applications for Accelerated Payments (Part A providers) in light of historical direct payments made available through HHS’s Provider Relief Fund. Significant additional funding will continue to be available to hospitals and other healthcare providers through other programs.

For more information on the CARES Act Provider Relief Fund and how to apply, visit  

View the
CMS Fact Sheet (PDF, 145 KB): Expansion of the Accelerated and Advance Payments Program for Providers and Suppliers During COVID-19 Emergency.

Please note that the information in these FAQ is subject to change due to CMS direction for the Public Health Emergency.

1. Question: What is the repayment plan for AAPs?

Answer: All providers may submit a voluntary refund of the AAP at any time (see FAQ 4 for how to voluntary refund). Automatic 100 percent repayment will begin 120 days after the issuance of the AAP in the form of payment offset. A payment offset is a withholding of overpayment amounts on future Medicare payments.

2. Question: Will Medicare add interest to the recoupment for the AAPs?
Answer: Interest will not accrue until the uncollected AAP balance has been demanded. Demand letters will not be issued for the uncollected amounts until day 210 (120 + 90 days of recoupment without interest) for most Part A and Part B provider/supplier types or day 365 (120 + 245 days of recoupment without interest) for providers who fall under the CARE Act (inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and Critical Access Hospitals [CAH]). Only after the demand letter has been issued will interest accruals begin.

3. Question: What is the interest rate that will be charged?

Answer: If interest is accrued, it will be at the rate applicable when a demand letter is issued and will be noted on the demand letter.

4. Question: Can I repay in a lump sum?

Answer: Palmetto GBA offers several options to repay an APP. We highly recommend using eServices, through the eCheck function. This option is secure, fast and easy. However, you may still submit a hardcopy form. You will need to access the hardcopy form, which is titled “Voluntary Refund Overpayment — Check Enclosed.” You will access the form on the Palmetto GBA website under Forms/Tools, then Finance/Overpayments. Please indicate “COVID-19 Accelerated/Advance Payment Repayment” on the check or in the documentation submitted with the paper check. Do not complete any patient and claim information section on the hardcopy form.

To use eServices, and if you are a provider administrator, you may access the eCheck sub-tab under Financial Tools, entitled “Financial Forms.” If you are a provider user, you must be granted permission to the Financial Tools tab by your provider administrator. The form is dynamic and contains edits to ensure that the information needed to process the payment is entered. Please make the below selections on the form to avoid the required entry of patient/claim information. 

The eCheck function allows payments to be sent electronically to Palmetto GBA. By using the eCheck option and selecting the option within the eCheck form indicating the payment is not associated with a demand letter, voluntary refunds can be submitted. There is no transaction fee for submitting an eCheck payment. In the form, please upload a document stating the payment is related to repaying of an AAP.

For more information, please review the Financial Tools Section in the eServices User Manual.

5. Question: Will I receive an overpayment demand letter before offsets occur?

Answer: After day 120, recoupment will begin and will continue for 245 days for inpatient acute care hospitals, children’s hospitals, certain cancer hospitals, and Critical Access Hospitals (CAH) and 90 days for all other Part A and Part B provider/supplier types. No demand letter will be sent prior to recoupment starting after day 120. If the AAP is not fully collected via offset 90/245 days after recoupment begins, then a demand letter will be issued for the uncollected balance. If the AAP is fully recouped within 90/245 days after recoupment begins, then no demand letter will be issued.

6. Question: How will offset amounts appear on my Medicare Remittance Advice?


Home Health, Hospice and Part A Facilities


  • Any amount offset and applied to the accelerated payment refund amount will appear on the Remittance Advice summary page in the section labeled “Withhold From Payments,” then “Accelerated Payments.” That amount will then be deducted from the “Payments” section.

Part B Providers

  • Any amount offset and applied to the refund of the advanced payment will appear on the last page of the Remittance Advice with WO indicating the amount withheld with a CVDXXX reference number.

7. Question: When does offset occur?

Answer: Offset of the AAP will begin on the 121st day. Providers should make note of the date their refund is due based on the date their AAP was issued and plan accordingly.

8: Question: What happens if I want to send a full refund in instead of allowing the amount to offset and my full refund doesn’t reach Palmetto GBA before offset begins?
Answer: Once Palmetto GBA receives and applies the lumpsum refund amount, Palmetto GBA will refund any amount collected over the AAP amounts providing there are no other outstanding overpayments that the money must be applied to.

Providers can avoid this by planning accordingly for their refund to reach Palmetto GBA in enough time for the refund to be worked and applied to the AAP refund amount before the start date of offset. 

9. Question: Will my entire Medicare payment be taken in offset?

Answer: Yes. Once offset begins, all future payments will be offset until the AAP amount has been refunded. Recoupment of payments can also be made from "affiliated providers." An affiliated provider is a provider that shares the same Tax Identification Number (TIN) and/or is noted as part of a Hospital Group (i.e., sub-units). On the Electronic Remittance Advice (ERA), a code of "OA" is used for Part A Affiliated Withholdings and a code of "OB" is used for Part B Affiliated Withholdings. The affiliated withholding amount is reported in the total withhold of the payment recap section on the Standard Paper Remittance (SPR).

10. Question: I requested and received two AAPs at two different times that total the full amount we were entitled to. When do I have to start paying the total amount back?

Answer: Current instructions indicate each payment would have a different due date. Therefore, there will be two offset start dates for the two payments issued, each equal to 120 days from the date of each individual payment.

11. Question: Should I hold my claims once offset begins so that my Medicare payments are not offset?
Answer: Palmetto GBA does not recommend providers take this action as interest will be accruing on any overpayment balance 30 days following the issuance of the overpayment demand letter.

12. Question: Do providers have the option to submit a Request for Extended Repayment Schedule (ERS)?

Answer: Providers are not eligible for ERS at this time, because the debt has not been demanded.

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