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Overpayments

Noridian collects provider overpayments through the acceptance and settlement of cost reports, claims account receivables, and through the quarterly credit balance analysis. Cost report settlement overpayments can be realized at the Initial cost report acceptance, Tentative Settlement, Final Settlement, Rate review, or Reopening of an already finalized report.

Demand Letters

After Noridian issues a demand letter for a cost report settlement, providers have 15 days to make payment before the claims payment system (FISS) is set up for withholding. Providers have 30 days from the date of the letter to reimburse Medicare before interest will accrue on the outstanding balance. Claims Account Receivables are demanded when the receivable balances have been outstanding without FISS system collection for over 60 days. On Claims Account Receivable balances, withholding is constant through the entire collection process. Interest will begin to accrue (in 30-day increments) on balances remaining uncollected over 90 days.

The date of the demand letter (not the day after) is the first day of the first 30 day period. Example: Demand letter is dated October 10th. A check would need to be received on or before October 24th (day 15). If the balance is still outstanding on November 8th (day 30), interest will accrue on November 9th (day 31).

Per CMS regulations, all checks being sent by providers to payoff settlement overpayments must be received in our office within 15 days of the demand. As a means of collecting settlement overpayments, all unpaid balances will be put on withhold if a check is not received by day 15 of the demand. All demand letters ask providers to notify our office immediately if a check is being sent and provide the name and phone number of the overpayment specialist in charge of collection efforts. If the check will be sent using certified mail, please notify Audit Support of the tracking number as well as the check number and the amount of the check.

Sending a Part A Overpayments Check

When submitting a check to Medicare for a Part A provider overpayment:

  • Include a copy of the demand letter to help ensure monies are applied properly.
  • Make check out to "Medicare Part A." Include provider number and applicable fiscal year end on check.
  • Mail check and demand letter copy to appropriate address available on the Mailing Addresses page of the Contact section.

Overpayment Interest Rates

Medicare Regulation 42 CFR Section 405.378 provides for the charging and payment of interest on overpayments to Medicare providers. The Secretary of Treasury certifies an interest rate quarterly by utilizing the most comprehensive data available on consumer interest rates. Interest is assessed on delinquent debts in order to protect the Medicare Trust Funds.

Extended Repayment Schedule

Noridian uses CMS guidelines when considering an Extended Repayment Plan and the withholdings during the application review process. Providers have access to this information within all demand letters mailed by Noridian.

Applying for an Extended Repayment Plan

  1. Anytime a provider needs longer than 30 days to repay the full amount of an overpayment, the provider should request an Extended Repayment Plan (ERP). While a provider may request an ERP at any time during the debt collection process, submittal within the first 15 days may decrease the necessity to withhold all interim payments.
  2. If the ERP request is received within 15 days of the date of the demand letter and it is complete and the first payment is included, interim payments will not be withheld unless interim payments are currently being suspended or withheld for another outstanding overpayment or investigation.
  3. If a provider notifies Noridian within 15 days that they intend to submit an ERP request, but cannot submit the required documentation within 15 days, 30 percent of interim payments will most likely be withheld. However, if a complete ERP application and first payment is not received by day 30 all interim payments will most likely be withheld.
  4. If Noridian does not hear from the provider regarding an ERP application within 15 days from the date of the demand letter, we will begin to recoup the overpayment by withholding a percentage of interim payments.
  5. Any payments withheld will be applied to the outstanding overpayment and will not be refunded.
  6. Any request for an ERP greater than 12 months must be forwarded to CMS for approval
  7. Any approved ERP will run from the date of the initial demand letter.
  8. The provider must continue to submit monthly payments until written approval/denial is received. If a provider fails to continue to submit monthly payments, we may initiate withhold of interim payments.
  9. Any questions should be directed to an Audit ERP Analyst by calling the Noridian Provider Contact Center
  • Extended Repayment Plan Application Form [PDF]
    A copy of this form and all the listed items must be submitted to Noridian in order to begin in the process of determining financial hardship. If you are unable to furnish one or more of the required documents, submit a statement explaining the reason for the delay or inability.

Immediate Offset Request

Providers may elect to have Noridian immediately take the next issued payment for the provider and apply it to a specific, defined overpayment or they may elect to have all future overpayments immediately "offset" from the next scheduled payment(s). The election of this process does not eliminate a provider's rights to an appeal.

 

Last Updated Jan 05, 2017