Satisfying an Overpayment

At Reconciliation, an overpayment may exist on an application for the following reasons: the sum of previous payment request(s) exceeds the current subsidy amount based on the most recent Allowable Retiree Costs and/or the Mandatory Payment Reduction.

In addition, if a Plan Sponsor fails to meet the Reconciliation Deadline for an application and has received interim payments, the sum of those payments will become overpayments.

When there is an overpayment, CMS will initiate immediate overpayment recovery action.

Note: For explanations and examples of common scenarios resulting in an overpayment at Reconciliation, refer to Avoid an Overpayment at Reconciliation in the RDS User Guide.

If there is an overpayment, the Reconciliation: Review and Submit page will display the Amount of Reconciliation Payment Request as a negative number in red font in parentheses.

The Review Subsidy table displays the Net Total in the Subsidy Amount column for the entire application. If there is an overpayment, the Net Subsidy Amount will display as a negative number in red font in parentheses.

The Benefit Option Summary table displays the Net Subsidy Amount for each Benefit Option in the application. If there is an overpayment, the Net Subsidy Amount will display as a negative number in red font in parentheses.

The Amount of Reconciliation Payment Request and the Net Subsidy Amount will be the same.

When CMS determines that your application has an overpayment, two emails will be sent to your Authorized Representative, Account Manager, and Designees with Appeal privileges:

• Overpayment Notification from the RDS Center stating that you have a balance due
• Invoice from J.P. Morgan Chase with a one-time payment link

Pay after receiving the invoice.

The RDS Center will email your Authorized Representative and Account Manager an "Overpayment Notification of Reduction of Balance" after applying your payment.

If you received an Overpayment Notification email and have requested Reconsideration or Reopening, you must remit payment. Until CMS' RDS Center makes a decision on your request, the Overpayment Notification email is considered the final Reconciliation determination, and payment must be remitted based on such determination.

Plan Sponsors must submit overpayment remittances electronically via the J.P. Morgan Chase payment portal. No other methods of payment are accepted by CMS' RDS Center.

J.P. Morgan Chase (the RDS payment processor) will send an email invoice to the Plan Sponsor’s Authorized Representative, Account Manager, and Designees with Appeal privileges when the overpayment is determined. This email will contain a one-time payment link to remit payment online. Payment is due upon receipt of this email.

Refer to Satisfy an Overpayment for additional information.