Overpayments and Recoupment - JA DME
Overpayments and Recoupment
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.
- Extended Repayment Schedule (ERS)
- Immediate Recoupment or Offset
- Limitation on Recoupment
- Overpayment Interest Rates
- Overpayment Monetary Threshold
- Overpayment Rebuttal
- Recovery Auditor Overpayments
- Surety Bond
- Voluntary Refund
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.
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.
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.
- 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