CR 10776 (PDF, 192 KB) was issued on May 24, 2019, to require demand letters be sent to HHAs when an overpayment is issued due to the Request for Anticipated Payment (RAP) cancelling when no HH Final Bill was submitted.
Prior to CR 10776, if a RAP cancelled because no HH Final Bill was submitted, an overpayment would be established, NO demand letter was sent initially; the cancellation appeared on the remittance advice, and the overpayment was eligible for an offset, immediately. Because no demand letter was issued, interest would not accrue on the overpayment. If the overpayment had an open balance after aging 60 days, the overpayment was aggregated with any similar overpayments, and a demand letter was issued. This would then make the debt eligible for interest accrual.
If a RAP cancels because no HH Final Bill was submitted, the overpayment will be established and the cancellation will appear on the remittance notice. Effective October 7, 2019, a demand letter will be issued and the overpayment will not be eligible for an offset until the 41st day. In this case, interest will accrue on the overpayment beginning on the 31st day of delinquency. In addition, the overpayment will not be eligible for appeals. Please refer to Publication 100-06 Medical Financial Management Manual, Chapter 3 (PDF, 549 KB), Sections 200.1.1 and 200.1.2 and Publication 100-04 Medicare Claims Processing Manual, Chapter 10 (PDF, 749 KB), Sections 10.1.10 through 10.1.12.