Supplier Options - Recovery Auditor Overpayment Determination

Available Options

Discussion Period

The discussion period offers the opportunity for the supplier to provide additional information to the Recovery Auditor to indicate why recoupment should not be initiated. It also offers the opportunity for the Recovery Auditor to explain the rationale for the overpayment decision.

Timeframe
  • Automated Review: Supplier has 30 days from date of Initial Findings letter to request a discussion period
  • Semi-Automated and Complex Review: Supplier has 30 days from date of Review Results letter to request a discussion period
  • On 31st day of Initial Findings or Review Results letter being sent, if no discussion period request has been received by Recovery Audit Contractor, claim will be sent to MAC for adjustment
  • Offset begins on 41st day of demand letter being sent

Rebuttal

A rebuttal should be submitted only on rare occasions of financial hardship. The rebuttal process allows the supplier the opportunity to provide a statement and accompanying evidence indicating why the overpayment action will cause a financial hardship and should not take place. A rebuttal is not intended to review supporting medical documentation nor disagreement with the overpayment decision. A rebuttal should not duplicate the Redetermination process.

Timeframe
  • Day 1 - 15 from date of demand letter

Redetermination

A Redetermination is the first level of appeal. A supplier may request a Redetermination when they are dissatisfied with the overpayment decision. A Redetermination must be submitted within 30 days of the Recovery Auditor decision to prevent offset on day 41.

Timeframe
  • Day 1 - 120
  • Must be submitted within 120 days of receipt of demand letter.
  • To prevent offset on day 41, the Redetermination must be filed within 30 days.
Last Updated Nov 10 , 2025