CMS Pub. 100-06, ch. 5, § 410.4

When Identifying Information is Provided

(Rev. 315, Issued: 05-17-19, Effective: 06-18- 19, Implementation: 06-18-19)

The term Medicare beneficiary identifier (Mbi) is a general term describing a

beneficiary's Medicare identification number. For purposes of this manual, Medicare

beneficiary identifier references both the Health Insurance Claim Number (HICN) and

the Medicare Beneficiary Identifier (MBI) during the new Medicare card transition

period and after for certain business areas that will continue to use the HICN as part of

their processes.

The following instructions shall not supersede the present Program Integrity Manual

(PIM) that references procedures for handling unsolicited refunds where there is a

voluntary repayment and referral to law enforcement. The following procedures shall be

followed when unsolicited/voluntary refund checks are received:

1) Do not return any check submitted by a provider/physician/supplier and other

entities that is made payable to the Medicare program.

2) To ensure that repayment of Medicare funds is handled properly, Medicare

contractors shall deposit such a check within 24 hours of receipt in accordance

with Chapter 5, Financial Reporting Manual, section 100.3 and record the check

in the account entitled “Other Liabilities – Unapplied Receipts” per Form CMS-

750 instructions found in Chapter 5, Financial Reporting, Section 210.

3) If any checks are not deposited within the 24-hour period, contractors shall

record those undeposited checks in the account entitled “Assets/Cash –

Undeposited Collections” per Form CMS-750 instructions found in Chapter 5,

Financial Reporting, Section 210. Medicare contractors shall implement

internal controls to ensure the safeguarding of these Medicare checks until

deposit.

4) If the specific Patient/Medicare beneficiary identifier information was provided,

the contractor shall deposit the check and make/initiate the appropriate

adjustments, depending on the entity making the refund and the purpose of the

refund, either to the claims and/or to the claim history file within 60 days from

the check’s date of deposit for Non-Medicare Secondary Payer (MSP), or 100

days from the initial ECRS inquiry for MSP. For those contractors whose

checks are received through a locked box, appropriate claims adjustments shall

be updated within 60 days of receipt of the bank’s notification of deposit for

Non-MSP, and 100 days from the initial ECRS inquiry for MSP.

5) If the provider/physician/supplier, or other entity is not participating in the Self-Disclosure Protocol, contractors shall ensure that any MSN, or Remittance

Advice, generated as the result of the claims adjustment contains appeals

language, where appropriate. If necessary, contractors should determine the

proper handling of unsolicited/voluntary refunds on any open or re-openable

cost report.

6) No appeal rights shall be afforded, as stated in Exhibit 1, if the

provider/physician/supplier, or other entity 1) does not submit the specific

Patient/Medicare beneficiary identifier information, or 2) is participating in a

Self-Disclosure Protocol agreement.

7) The Medicare contractor shall establish an accounts receivable in the Medicare

system that shall be recognized on line 2a, New Accounts Receivable on Form

CMS-751 report within 60 days after the deposit of the voluntary refund for

Non-MSP, or 100 days from initial ECRS inquiry for MSP. In addition, the

Medicare contractor shall reduce the “Other Liabilities” account for the same

amount, and shall apply the refund to the established accounts receivable and

recognize the collection on line 4a, Cash/Check Collections on Form CMS-751

report.

8) The accounts receivable shall be established using the last name of the debtor

that issued the check or on whose behalf the check was issued, as well as the

debtor’s employer/tax identification number and/or provider or beneficiary

number. If the debtor’s employer/tax identification number or provider or

beneficiary number is unavailable, then the first four letters of the debtor’s name

and last four digits of the bank account number on the check shall be used as

identifying information for setting up the accounts receivable. All Medicare

systems shall have the ability to manually complete this procedure.

9) If the amount of the unsolicited/voluntary refund check exceeds the amount of

the original claim, Medicare contractors shall check all categories of open

account(s) receivable for that provider/physician/supplier or other entity

including those established as a result of medical review, benefit integrity (BI)

review, cost reports, other overpayment demands, and MSP demands. If an

outstanding receivable is identified, the contractor shall apply the remaining

amount of the unsolicited/voluntary refund to the outstanding receivable

balance. If there are multiple outstanding accounts receivables, then the excess

funds should be applied to the oldest accounts receivable first – interest then

principal.

10) Medicare contractors shall not automatically refund excess recoupments to the

provider/physician/supplier, or other entity. Contractors shall only refund

excess recoupments when no other outstanding accounts receivable exists, or

written documentation/evidence clearly supports that Medicare is not entitled to

the money or was not the intended recipient of the refund check. Contractors

shall follow the non-MSP provider/physician/supplier refund process when

encountering MSP provider/physician/supplier unsolicited/voluntary refunds.

Monies voluntarily sent in from beneficiaries (or a representative of) and/or

insurers or other third party payers may be refunded only if COBC determines,

after 100 days, no issue exists or an issue exists which results in the lead

contractor identifying Medicare’s claim to be less than the refunded amount.

For example, many times an attorney may remit payment for the total

conditional amount prior to a formal demand.

11) The Medicare contractor shall be responsible for completing Exhibit 1 (or

facsimile thereof) as appropriate and reporting it on Exhibit 2.

12) Contractors are not required to report the established accounts receivable on the

Physician Supplier Overpayment Reporting System (PSOR). (This requirement

does not preclude the contractor from reporting the receivable on the PSOR for

non-MSP, if current systems already do so. The contractor shall not report MSP

accounts receivable on the PSOR.)