US · guidance
CMS Pub. 100-06, ch. 3, § 200.2.2
Recoupment After the Initial Demand: When Does it Begin?
Timeframe Medicare Contractor Provider
Day 1 Send demand letter. Receives notification by first class
mail of overpayment determination.
(The letter date is the determination
date).
Day 1-15 Process rebuttal
requests received
before or by day
15 deadline. No
recoupment occurs.
Can submit a rebuttal request within
15 days from the date on the demand
letter. (The letter date is the
determination date). Can request an
Immediate recoupment
Day 16-30
Process rebuttal
requests received
before or by day 15.
Performs administrative
activity (i.e., validating
Redeterminations and
updating account
receivables to the
Redetermination
status).
No recoupment occurs
unless the provider
requested the
Immediate
Recoupment
Can request a redetermination and
potentially prevent any recoupment
from occurring on day 41.
Day 31-40 Performs administrative
activity (i.e. validating
Redeterminations and
updating account
receivables to the
Redetermination
status).
No recoupment occurs
unless the provider
requested the
Immediate
Recoupment.
Can request a redetermination and
potentially prevent any recoupment
from occurring.
Day 41 Recoupment begins on
overpayments without a
validate
redetermination
request.
Can request a redetermination and
potentially stop recoupment from
continuing.
1. Recoupment shall proceed on day 41 (with the exception of
immediate recoupment) from the initial demand letter without a
timely and valid request for a redetermination.
2. To prevent recoupment from occurring on day 41, the
provider must file the request for a redetermination no later than
the 30th calendar day following the date of the initial demand
letter.
3. Contractors shall refer to Publication 100-04 Medicare
Claims Processing Manual, Chapter 29, and Appeals of Claims
Decision, to determine what constitutes a valid request for a
redetermination.
4. Contractors shall have internal controls in place to ensure
when a provider is in an immediate recoupment status
the recoupment process continues unless a request from the
provider is received to stop the immediate recoupment.
5. Contractors shall continue to stop recoupment on or after
day 41 from the demand letter date when the appeal request is
received and validated with an outstanding balance.
• Providers have 120 days after the date of receipt of the initial
determination (the notice of initial determination is presumed
to be received 5 days after the date of the notice unless there is
evidence to the contrary) to request a redetermination in
accordance with Publication 100.04, Chapter 29
History
(Rev. 311, Issued: 02-22-19, Effective: 10-07-19, Implementation: 10-07-19)
Provenance
- Source
- cms.gov
- Retrieved
- 2026-08-25
- Edition
- iom-2026-08-25
- Content hash
797ee8a5efb673572a5c311969a626555c1d49c8b82035b4a027b98fa5b69a41
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