Overpayment Rebuttal Process

You’ll need to know what the rebuttal process is before initiating and know that the outcome of the rebuttal may not change the National Government Services recoupment process.

The overpayment rebuttal process is a protocol used when an account receivable has been set up on a claim(s) and a demand letter has been sent to a provider/supplier.

If providers/suppliers have reason to believe the withhold should not occur, providers/suppliers will have 15 days from the date of the demand letter to notify NGS of rebuttal. The rebuttal may not change the NGS recoupment process.

The rebuttal process is not an appeal of the overpayment determination, it’s a statement of opportunity for providers/suppliers to refute an overpayment and the rebuttal process will not delay the recoupment process.

Under existing regulation 42 CFR section 405.374, providers/suppliers will have 15 days from the date of the demand letter notification to submit a statement of opportunity to rebuttal, including a statement and/or evidence stating why the recoupment should not be initiated. NGS will review the provider/supplier’s documentation and render a decision in 15 days from receipt of provider/suppliers rebuttal request.

Provider/supplier may submit a rebuttal when there is good cause to believe that NGS should not withhold claim payments or offset or recoup on an account receivable.

Common Reasons to Why a Provider/Supplier Would Submit a Rebuttal

Repayment for overpayment has already been submitted
Overpayment was created in error
Overpayment was created for a full, instead of a partial claim adjustment, and a clarification is included with rebuttal statement

Request for Rebuttal Submissions

Shall indicate "Rebuttal" in subject line or first sentence of document and on envelope
Clearly state reason for rebuttal and include supporting documentation
Include a copy of original overpayment letter with rebuttal statement

If original overpayment letter is not available, the rebuttal request shall include:

Supplier's name
NPI or PTAN
DCN
Beneficiary Medicare number
Date of service

Providers/suppliers will be required to mail rebuttals with a copy of the demand letter to the appropriate contractor mailing address as shown below.

Jurisdiction K: CT-MA-ME-NH-NY-RI-VT
National Government Services Rebuttal Process
P.O. Box 7111
Indianapolis, IN 46207-7111

Jurisdiction 6: IL-MN-WI
National Government Services Rebuttal Process
P.O. Box 6475
Indianapolis, IN 46206-6475

Related Resources

Reviewed 10/17/2024