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Last Modified: 1/17/2018 Location: FL, PR, USVI Business: Part A, Part B

Limitation on recoupment (935) process

Contractor timelines and audit explanations

The information below outlines the process for the 935 recoupment due to changes from the Centers for Medicare & Medicaid Services (CMS) through change request (CR) 6183 -- limitation on recoupment of section 935 for provider, physicians and suppliers overpayments.
Contractor’s recoupment timeline

Contractor action
Day 1
Date demand letter mailed
Day 1-15
Rebuttal submission deadline
A rebuttal request may/may not stop a debt from being collected. Only a valid and timely request for redetermination will stop the collection.
Day 1-30
Submit refund payment in full, or request a valid appeal
No interest accrued
Day 31
Interest accruement begins
Accruement continues until debt is fully satisfied. Fully satisfied means paid in full or overturned by appeal.
Day 1-40
No recoupment occurs
Day 41
Recoupment begins
Unless an appeal is in process
General notes
Providers have 15 days to rebut any proposed recoupment
To stop recoupment, providers may either pay the recoupment in full, or file a redetermination appeal or reconsideration
An administrative law judge (ALJ) request will not stop recoupment
A redetermination can have three possible outcomes:
1. Favorable
2. Unfavorable
3. Partially favorable
After receiving a valid request for a redetermination appeal, the contractor will:
1. Stop recoupments subject to appeal,
2. Retain any overpayments previously collected and apply first to the interest and then to the principal of any other debt provider may owe, and
3. Continue to collect on any other debt owed by provider, but will not withhold monies related to the current debt while it is in an appeal status.
Recoupment will begin on the 41st day if one of the following three actions do not occur:
1. Payment is not made in full,
2. An extended repayment schedule is not requested, and
3. A redetermination or reconsideration is not made within the appropriate timeframe.
Appeals process
Click here to access an outline of the appeals process.
Note: The redetermination process can begin anytime from day 1 to day 120. After 120 days, an appeal will not be accepted.
Reference: Medicare Learning Network® (MLN) Matters article MM6183 and Medicare Overpayments external pdf file brochure.
First Coast Service Options (First Coast) strives to ensure that the information available on our provider website is accurate, detailed, and current. Therefore, this is a dynamic site and its content changes daily. It is best to access the site to ensure you have the most current information rather than printing articles or forms that may become obsolete without notice.