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:

  1. Provider name and phone number
  2. Provider Medicare number and/or National Provider Identifier (NPI)
  3. Provider or CFO’s signature
  4. Demand letter number
  5. 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.

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5 Responses to “CMS Starts Immediate Recoupment for Overpayments”

  1. Brandi Tadlock says:

    FYI: The hyperlink for the transmittal takes you to this message:

    “Transmittal 204, dated January 27, 2012, is being rescinded and replaced by Transmittal 205 dated February 9, 2012, to restore Exhibits 2 through 6 that were erroneously omitted in the original transmittal. All other information remains the same.
    SUBJECT: Immediate Recoupment for Fee for Service Claims Overpayments”

    MLN Matters Article: http://www.cms.gov/MLNMattersArticles/downloads/MM7688.pdf

  2. Krystal says:

    I am the VP of Finance for a LTC pharmacy that services it’s own facilities. We have this problem currently. We get a demand overpayment letter, cut a check in a very timely manner to only then also get recouped. We even call the number on the letter to state we are sending the money back. I would suspect it sits on CMS desk and they do not process timely. However we do not want to be flagged as a “non-responder”. Suggestions?

    Is anyone else experiencing this? Any insight is helpful.

    Kind Regards

    Krystal

  3. Janice says:

    When I get a demand overpayment letter I go to Csnap to forms and select the “Immediate Offset Request.” Fill it out with the date of the demand letter and also the letter number as well as your name, phone number, practice name, NPI, PTAN, and last five of your Tin.. Print this and fax it to the number on the form. This will automatically be a write off on a future remit advice. This works if you get electronic remit advices. I don’t know how you are set up. We never issue a paper check in this instance. Works like a charm

  4. kim says:

    I think the new option for “immediate recoup” will be great. Even when you are timely, writing checks never seemed to work, as with Krystal, they take the money anyway, then there’s the whole nightmare of getting it back. I like the paper trail left by an auto recoup. Unless you dispute the takeback, let them do it : )

  5. Gale says:

    We have trnsitioned to our permanent MAC just recently (OHIO-CGS). I recieved the “Results Letter-Overpayment” Feb 14, however it was dated Jan 3 but to date have not recieved a “Demand Letter” but there was a recoupment in today’s transmittals. We have not had any luck being able to register or give CGS the dedicated PO Box that we use for R activity, does anyone have any ideas?

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