CMS Pub. 100-06, ch. 3, § 200.1.7

Contractors shall offer providers the opportunity to request immediate recoupment. Providers

can elect this process to avoid making payment by check and/or avoid the assessment of interest

if the immediate recoupment pays the debt in full before day 31. If providers request an immediate

recoupment, they must understand that it is considered a voluntary repayment. The request for

immediate recoupment should be received in writing at least 16 days from the date of initial demand

letter to avoid the assessment of interest, however when the request is received after 16 days

from the date of the demand letter, the debt shall be placed in an immediate recoupment

status and interest will continue to accrue if the debt is not fully collected by day 31.

A. Contractors shall offer two immediate recoupment options.

1. A one-time request on the total overpayment amount (All accounts receivables) in a

single demand letter and any future demanded overpayments; Or

2. A request on the demanded overpayment (All accounts receivables) addressed in

a single demand letter only.

B. Contractors shall incorporate the following minimum information related to “immediate

recoupment” on its website:

1. This option is ONLY for overpayments that receive a demand letter.

• The request must be in writing, and may be submitted using regular mail,

Facsimile, or email with an encrypted file.

• The request must include the following:

1. Provider Name and contact phone number

2. Provider’s Medicare Number and/or the National Provider Identification (NPI)

3. Provider, Administrator or CFO’s signature (someone with authority is

required to sign)

4. Letter number or a copy of demand letters first page

5. Which option the provider is requesting

• The contractor shall scan, copy or keep the original request for proof of receipt.

2. Contractors shall use their discretion when a provider does not submit all 5 requirements to

either:

• Reach out to provider for the missing information or

• Not accept the request based on missing information

3. Contractors shall continue to maintain or update the website on the immediate recoupment

process as needed.

C. Contractors shall inform providers that going through the immediate recoupment

process is considered voluntary payments and will not be subject to 935 (f)(2)

interest pursuant to § 1893(f)(2).

D. Contractors shall consider all written requests for an immediate recoupment as a

payment arrangement that constitutes a voluntary payment except for immediate

recoupment 30 calendar days after reconsideration decision.

• When the provider appeals to the ALJ and prevails.

1. Any money recouped (applied to the principal balance) 30 days

after the reconsideration decision will be subject to 935 Interest.

2. Contractors shall follow the 935 (f)(2)interest calculation rules when the

provider prevails and recoupment continued after an unfavorable

reconsideration decision.

E. Contractors shall ensure the demand letter and website explain that, when there is a

remaining principal balance after the initial immediate recoupment, they shall continue

recoupment and other collection activities.

F. Contractors shall update all ARs associated to the request within 14 calendar

days from the Mailroom-stamped receipt date.

G. As applicable, contractors on HIGLAS shall use the functionality in HIGLAS,

which allows user to set the flag to immediate recoupment for multiple ARs

instead of only one AR.

H. Contractors shall update ALL AR’s within the demand letter(s) in the shared

systems when a provider requests the immediate recoupment option.

I. Contractors shall accept a written request to discontinue participation in the immediate

recoupment process at any time. Once received, Contractor’s shall stop the

immediate offset process as soon as possible from the mailroom receipt date, but

no later than 14 calendar days from mailroom receipt date.

J. Contractors shall consider all written requests for an immediate recoupment as a

payment arrangement that constitutes a voluntary payment.