Overpayments and Recoupment - JA DME

Many situations may cause a supplier to owe Medicare money on previously paid claims.

• Noridian initiated claim edit correction
• Contractors claim reviews (Noridian, Recover Auditor, Comprehensive Error Rate Testing (CERT), Office of Inspector General (OIG), etc.)
• Claim paid when should have denied had all beneficiary services been submitted in sequential order (e.g., Skilled Nursing Facility (SNF) or hospital admissions)
• Changes to beneficiary's eligibility as maintained by Social Security Administration (e.g., date of death, cancelled policy, election of a Managed Care Plan)

Access the below related information from this page.

• Bankruptcy
• Extended Repayment Schedule (ERS)
• Immediate Recoupment or Offset
• Limitation on Recoupment
  • Request Redetermination
• Overpayment Interest Rates
• Overpayment Monetary Threshold
• Overpayment Rebuttal
• Recovery Auditor Overpayments
• Surety Bond
• Voluntary Refund
• Resources

Overpayment Monetary Threshold

CMS requires the DME MAC to request refunds on overpayments of $25 or more. If a supplier owes several small overpayments, each of which is less than $25, the total amount owed will be aggregated at the end of the month. DME MACs will accept refunds of less than $25. A supplier must submit specific documentation to support the extended repayment plan request.

Overpayment Rebuttal

A supplier may submit a rebuttal when there is good cause to believe the DME MAC should not withhold claim payments to offset a recouped account receivable.

Common Reasons to Submit a Rebuttal

• Check has been submitted for payment
• Overpayment was created in error
• Overpayment was created for a full, instead of a partial claim adjustment, and a clarification is included with rebuttal statement

Request Rebuttal in Writing (E.g. Business Letter or Memo)

To ensure correct processing:

• Clearly indicate "Rebuttal" in subject line or first sentence of document and on envelope
• Clearly state reason for rebuttal and include supporting documentation, e.g., cashed checks
• Include a copy of original overpayment letter with rebuttal statement. If original overpayment letter is not available, include below in rebuttal
  • Supplier's name
  • National Provider Identifier (NPI) or Provider Transaction Access Number (PTAN)
  • Document Control Number (DCN)
  • Beneficiary Medicare number
  • Date of service (DOS)

Mail overpayment rebuttals to Noridian.

Rebuttal will be reviewed and a written response will be sent to the supplier.

If a supplier has a rebuttal question on a Recovery Auditor Overpayment, view the Recovery Auditor Determinations - Agree or Disagree webpage.

Voluntary Refund

A voluntary refund is a situation that causes a supplier to owe money to Medicare on a previously paid claim(s). Although Medicare may have not notified the supplier of this overpayment, a voluntary refund must be submitted.

To ensure proper recording and timely processing, submit your voluntary refund along with a check using the applicable completed "MSP Overpayment Refund Form" or "Non-MSP Voluntary Checks Refund Form" option from the Forms page. Instructional details and mailing address are included. To submit an overpayment refund request without enclosing a check, follow the instructions for submitting a Non-MSP Overpayment Refund Request.

Resources

• CMS Internet Only Manual (IOM), Publication 100-06, Medicare Financial Management Manual, Chapter 3
• CMS IOM, Publication 100-06, Medicare Financial Management Manual, Chapter 5
• CMS Change Request (CR) 6183 - Limitation on Recoupment (935) for Provider, Physicians and Suppliers Overpayments