Immediate Recoupment for Fee for Service Claims Overpayments

Effective July 1, 2012, The “immediate recoupment” process implemention allows providers to request that recoupment begin prior to day 41. Providers who elect this option may avoid paying interest if the overpayment is recouped in full prior to day 31.

Key to understanding this change is that providers who request an immediate recoupment must realize it is considered a voluntary repayment

1. Providers who choose immediate recoupment must do so in writing to the contractors. Also, note the following:

2. The request may be for:

a. a one-time request for a specific demanded overpayment (the total amount of the demanded overpayment); or

b. a permanent request for the specific demanded overpayment and all future overpayments.

3. The request may be submitted via regular mail, facsimile, or e-mail and the request must include the Provider’s name, contact phone number, Medicare number and/or National Provider Identifier (NPI), Provider or Chief Financial Officer's signature, demand letter number and what option the provider is requesting.

4. By choosing immediate recoupment, providers must understand that they are waiving their rights to interest under Section 935 of the Medicare Modernization Act (MMA) should the overpayment be reversed at the Administration Law Judge level (ALJ) or subsequent higher levels.

5. Providers can terminate the immediate recoupment process at anytime. The request to terminate must be in writing.

Reference: http://www.cms.gov/MLNMattersArticles/Downloads/MM7688.pdf

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