New Recoupment Options

The Centers for Medicare and Medicaid (CMS) recently issued new options for those facing recoupment of overpayments. Currently, when your local contractor has identified an overpayment, there is a delay of 40 days before they begin to recoup the overpayment from your EOBs.

Effective July 1, 2012, providers may elect recoupment to begin prior to the normal recoupment at day 41 after receipt of notice; interest is avoided if the overpayment is paid back in full before day 31.

The important points in MM7688 (Revised), issued January 27, 2012 are:

1. To accelerate recoupment, you must notify the contractor in writing. This means via postal service, FedEx or other alternative carrier, e-mail, or by fax.
2. You may elect a 1-time request for a specific demand letter or make it a permanent standing request.
3. You can terminate the request in writing at anytime.
4. Your written request must contain the following: Provider name and phone, Provider Medicare number and/or NPI, Provider or CFO signature, Demand letter number, Which option you are selecting (see link at bottom).
5. Your request must be received by the contractor no later than the 16th day from the initial demand letter.
6. When interest is assessed, it is done at simple interest of 10.50% according to 42 CFR 405.378, and begins on the 31st day. A hyperlink is provided here that contains the interest rate assessment particulars.
7. It is considered a voluntary repayment.
8. You are waiving certain rights to interest if the overpayment determination is overturned later. Follow the bottom link for information.

You can download CMS document MM7688 Revised by clicking on this link.

We believe providers should be aware of, but not necessarily elect this option without careful consideration. You are welcome to contact our office to discuss your options.