Immediate Recoupment or Offset

A supplier is sent an overpayment request letter that includes the Medicare processed claim(s) detail which led to the overpayment. It is the supplier's responsibility to refund overpayments. Suppliers should respond to the request for refund according to the instructions provided in the letter.

Suppliers may complete and submit the Immediate Recoupment Form to make a one-time request to have their account set to immediately offset debt from a current Medicare payment. This process gives suppliers the option to avoid interest from accruing on overpayments and the opportunity to continue with the appeal process, if needed. This can be selected for a single claim or a current claim and all future overpayments until the supplier otherwise notifies Noridian.

Request for Immediate Recoupment (Offset)

To reduce the effort suppliers may spend obtaining a check and sending the related paperwork to Noridian in response to an overpayment request letter, suppliers have the option to use a process outlined in CMS Change Request (CR)7688 to have their Medicare account set to immediately offset/withhold payment for debt from a current Medicare payment. Submit request in one of below ways.

This does not impact a supplier's ability to appeal an overpayment. Suppliers are encouraged to review the below information to determine if initiating an immediate offset indicator for their future debt would be beneficial for their business practice.

Suppliers may elect to have overpayment(s) repaid through the "immediate recoupment" process and avoid paying by check or waiting the standard recoupment process that begins on day 41 from the date of the demand letter. This process is voluntary and for supplier's convenience. If used, a supplier it is not required but suppliers are encouraged to use the Immediate Recoupment Form; however, suppliers can submit their own request as long as it contains all of the following seven elements:

  1. Provider/Supplier Name
  2. Contact phone number
  3. Supplier's Provider Transaction Access Number (PTAN) and/or National Provider Identification (NPI)
  4. Signature of supplier or Chief Financial Officer (CFO)
  5. Letter number to identify debt (i.e., Document Control Number (DCN))
  6. Indication of which type of immediate recoupment is being requested. Suppliers must specify the type of request being submitted; however, request for immediate recoupment must be received in writing no later than 16 days from date of initial demand letter
    • A request for current overpayment address in this demand letter only, or
    • A one-time request for current overpayment and all future overpayments
  7. Supplier's request must specifically state he/she understand potential receipt of interest payment pursuant to Section 1893(f)(2) for overpayments is begin waived
    • Such interest may be payable for certain overpayments reversed at Administrative Law Judge (ALJ)

Benefits of Automatically Offsetting Debts

Depending on the claim payment activity a supplier has with Noridian, the "immediate recoupment" process gives suppliers the option to avoid interest from accruing on claims overpayments when the debt is recouped in full prior to or by the 30th day from the initial demand letter date. If the supplier does not appeal the identified overpayment, and the supplier has claim payment activity that would satisfy the debt, suppliers can avoid the administrative activity of creating the paperwork and sending Noridian a check.

Ability to Cancel Automatic Offset Election

A supplier may change their election by submitting the following information to the Noridian DME Recoupment team via fax, Email, or postal mail.

  • Provider/Supplier Name
  • Contact phone number
  • Supplier's PTAN and/or Suppliers' National Provider Identification (NPI)
  • Signature of the supplier or the Chief Financial Officer (CFO)
  • Indication that the supplier requests that an existing immediate offset indicator be removed from their file.

Notification Process and Appeal Rights Remain Unchanged

Noridian continues to mail supplier's notification overpayment letters with the details that were used to determine the debt. The letter defines the steps necessary to appeal the debt. If the debt is successfully appealed and the supplier has proven the claim was paid correctly, any debt and interest collected will be provided to the supplier and/or applied to any outstanding debt the supplier may have on file.

Overpayment Status Inquiries

Noridian offers suppliers three tools to determine the status of repayment for debt.

  1. Overpayment request letter are mailed to suppliers and contain detail of debt in addition to Financial Control Number (FCN)
  2. Use the Interactive Voice Response (IVR) to gain specific details about debt and collection activity
  3. Use the Noridian Medicare Portal (NMP) to gain details regarding what claim(s) caused the debt as well as what checks, offsets, and interest have been collected to satisfy debt

Immediate Offset is Contractor-by-Contractor Basis

If a supplier bills multiple DME Medicare Administrative Contractors (MACs), the supplier must initiate the immediate offset process with each DME MAC. When a claim number is used on the Request for Immediate Recoupment form, suppliers must ensure the claim number indicated is specific to the claim processed by that DME MAC.

Offsets to payments (recoupment) on Remittance Advice

Offsets (recoupments) to payments, are shown as an adjustment to the provider's payment at the summary level, rather than as an adjustment at an individual claim level on the remittance advice in the provider adjustment (ADJ) Details Section. Beginning April 1, 2024, the PLB Reason Code WO will now include the PTAN that caused the withholding. Please see the updated remittance advice field descriptions, included in the update from HIGLAS.

Remittance Advice

  • Offset as a result of a previous overpayment (A/R accounts receivable). Used to recover previous overpayment. A reference number (the original ICN and Medicare ID) is applied for tracking purposes.
    • Important Note: In HIGLAS when two or more providers are affiliated with multiple NPIs and have the same Tax Identification Number (TIN), payments may be withheld from one provider (PTAN) to collect another provider's (PTAN) overpayments.
    • Beginning April 1, 2024, HIGLAS has updated this field on the remittance advice to display the PTAN of the location that caused the withholding to occur.
    • For any remittance advice dates prior to April 1, 2024:
      When money is taken back by TIN, if the supplier cannot determine who (the PTAN) money is being taken back (recouped) from, call the Supplier Contact Center for your jurisdiction to obtain that information (suppliers may be required to leave a message and receive a call back).
    • Example: Supplier 123 (PTAN) in California receives remittance advice. An offset is taken back (recouped) from supplier 345 (PTAN) in Florida. Both suppliers are under the same TIN but supplier 123 is unable to locate the account in their accounts receivable. Contact the Supplier Contact Center for your jurisdiction to obtain this information.

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