CMS Starts Immediate Recoupment for Overpayments
The Centers for Medicare & Medicaid Services (CMS) is implementing an immediate recoupment process for demanded overpayments. As it stands, Medicare contractors begin recoupment of an overpayment on day 41 from the date of the initial demand letter. Effective July 1, 2012, however, providers can request recoupment to begin prior to day 41. Providers who elect this process may avoid the assessment of interest if the overpayment is paid back in full before day 31.
Providers who voluntarily choose immediate recoupment must do so in writing (by mail, FAX, or email) to contractors. The letter should contain the following information:
- Provider name and phone number
- Provider Medicare number and/or National Provider Identifier (NPI)
- Provider or CFO’s signature
- Demand letter number
- Which option the provider is requesting
Providers can elect a one-time immediate recoupment request for the current overpayment and all future overpayments or request immediate recoupment for a specific overpayment addressed in a demand letter.
A request for immediate recoupment letter must be received by contractors no later than the 16th day from the date of the initial demand letter.
In accordance with 42 CFR 405.378, simple interest at the rate of 10.50 percent (effective Jan. 19, 2012) will be charged on the unpaid balance of the overpayment beginning on the 31st day. Interest is calculated in 30-day periods and is assessed for each full 30-day period that payment is not made on time. In other words, if payment is received 31 days from the date of final determination, one 30-day period of interest will be charged.
Further details can be found in MLN Matters® article MM7688, issued Jan. 27, 2012.