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 circumstances causing a Plan Sponsor to be in an overpayment situation at the completion of 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 the Reconciliation Determination for an application is made, CMS' RDS Center will send an Overpayment Notification Email to the Plan Sponsor's Authorized Representative, Account Manager, and Designees with Appeal privileges stating that a balance is due. A payment is due immediately upon receipt of the Overpayment Notification Email.

Note: An overpayment remittance may be sent to CMS' RDS Center as soon as the overpayment notification is received.

CMS' RDS Center will send a Check Acknowledgement Email to the Authorized Representative and Account Manager to confirm the receipt of the overpayment remittance on the day the check or money order is received.

If you have received an Overpayment Notification Email and have requested an appeal, you must remit payment. Until an appeal decision is made by CMS' RDS Center, the Overpayment Notification Email is considered the final Reconciliation determination, and payment must be remitted based on such determination.

Refer to Send an Overpayment Remittance in the RDS User Guide for the mailing address for remitting a payment, as well as details for preparing the check or money order and how CMS' RDS Center acknowledges receipt of an overpayment remittance.