US · guidance
CMS Pub. 100-06, ch. 7, § 50.11
K Controls – Debt Referral (MSP and Non-MSP)
K – Control
Number
Control Objective – Debt Referral (MSP and Non-MSP)
K.1 Procedures are documented and followed to identify a debt eligible
for referral to Treasury for cross servicing and Treasury Offset
Program (TOP) prior to the debt becoming 120 days delinquent.
These procedures are written and available for review. Debts
eligible for referral and debts ineligible for referral are properly
reported on the appropriate CMS Forms 751, Contractor Financial
Reports, Status of Accounts Receivable, or the Treasury Report on
Receivables and Debt Collection Activities Report. For MSP debt,
see Internet Only Manual (IOM), Pub 100-05, MSP Manual,
Chapter 7, Section 60 and Chapter 4, Debt Collections.
K.2 Intent to Refer Letters (ITRs) for eligible debt are sent in a timely
manner in accordance with CMS instructions. Timeframes for each
type of debt can be found in the IOM, Chapter 4, Debt Collections.
K.3 Responses to the ITR letter are handled timely according to CMS
instructions. Appropriate systems are updated to reflect any changes
to the eligibility status of the debt and these statuses are properly
reported on the financial reporting forms outlined in K.1.
Procedures are in place to handle undeliverable letters. Refer to the
IOM, Chapter 4, Debt Collections.
K.4 All contractors review the system generated HIGLAS CMS Debt
Management (CMSDM) Return to Agency (RTA) report and update
HIGLAS accordingly to ensure appropriate debts are referred to
Treasury as follows:
• CMS contractors who have not transitioned to HIGLAS,
including the Administrative Program Accounting (APA)
line of business, ensure that the HIGLAS Debt Management
Module is updated timely for debt referrals as needed.
• HIGLAS contractors ensure that the HIGLAS AR
transactions are updated timely for debt referrals as needed.
K.5 When there is a change to a debt that has been referred for cross
servicing, CMS contractors who have not transitioned to HIGLAS,
including the APA line of business, update the HIGLAS Debt
Management Module to initiate recalls, collections, and adjustments
timely and accurately in accordance with CMS instructions.
HIGLAS contractors initiate recalls, collections and adjustments
timely and accurately by updating the HIGLAS Accounts
Receivable (AR) transactions as needed.
K – Control
Number
Control Objective – Debt Referral (MSP and Non-MSP)
K.6 All CMS contractors ensure that the CMSDM Treasury Collection
Report Spreadsheets are completed timely in accordance with CMS
instructions, and the appropriate source systems are updated as
follows:
• CMS contractors who have not transitioned to HIGLAS,
including the APA line of business, ensure that the HIGLAS
Debt Management Module is updated timely with
refund/adjustment information as needed.
• HIGLAS contractors, including the APA line of business,
ensure that the HIGLAS AR transactions are updated timely
and accurately with the refund/adjustment information as
needed.
K.7 Treasury Cross-Servicing Dispute Resolution forms are researched,
resolved, and responded to Treasury timely in accordance with
CMS instructions. Procedures are in place and are being followed to
respond to these disputes/inquiries, update the appropriate system,
and properly report the status and balance of the debt in the
financial reporting forms.
K.8 All CMS contractors ensure that the CMSDM RTA report
spreadsheets are completed timely in accordance with CMS
instructions and debts listed on the spreadsheet are properly
reported on the financial reporting forms in accordance with CMS
instructions. CMS contractors who have not transitioned to
HIGLAS, including the APA line of business, follow the RTA
Interface and Report instructions in the HIGLAS Debt Management
Module training guide.
K.9 Contractors ensure that debts have the correct status when the debt
is referred to Treasury and retains this correct status while at
Treasury.
End Section 50.11 – K Controls – Debt Referral (MSP and Non-MSP): Back to Table of
Contents
History
(Rev. 11133, Issued:11-30-21, Effective: 10-01-21, Implementation: 12-31-21)
Provenance
- Source
- cms.gov
- Retrieved
- 2026-08-25
- Edition
- iom-2026-08-25
- Content hash
fb8907127c1ce6e40cadb22f7700bdd4ea0dd3e2313fca0eddb9ea5c3c94e397
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