Palmetto Recoupment Educational Letter

Bill Finerfrock, Executive Director

07/02/2018

Palmetto Recoupment Educational Letter

For the past 10 days, NARHC has been communicating with officials from Palmetto and CMS regarding the recoupment letters sent to RHCs on June 15th. NARHC has been notified by officials from Palmetto that the following message will be distributed to the RHC Community & posted on the Palmetto listserv.

Jurisdiction J (JJ) Medicare Advantage (MA) Overpayment Issue

Postponement of Claim Cancellation/Recoupment: Palmetto GBA will extend the cancellation and recoupment date of these claims from July 1, 2018 to July 15, 2018, to allow providers additional time to research their patient account records and provide us with information to review and consider for exception.

Exception Requests: This two-week extension will allow providers greater opportunity to research and submit instances where they believe they should receive an exception to the claim cancellation and recoupment process. Valid exceptions might apply if the provider has already made payment through the Credit Balance Report, submitted payment in the form of a voluntary refund, or the provider can show that the Common Working File was updated to show the patient was NOT covered under an MA plan.

Submitting Exception Requests: If you believe you have a valid exception request, you may send an email to jj.prrs@palmettogba.com notifying us and including the documentation of your claim (the following are examples and not exhaustive of all possible forms of appropriate documentation):

Copy of cancelled check
Credit Balance Report documentation showing the listing of claims you requested to have cancelled
Proof of delivery receipt to Cahaba GBA

In addition, Palmetto has created a Frequently Asked Questions document that should answer some of the additional questions you may have. CLICK HERE for link.

NARHC would like to thank the staff at Palmetto for listening to the concerns raised by NARHC as well as many individual rural health clinics that contacted Palmetto directly. While we view this as a slight improvement in the situation, this does not go as far as we think is necessary or appropriate. It is important to keep in mind that this problem occurred because the previous Medicare Contractor failed to properly flag/return claims for beneficiaries enrolled in a Medicare Advantage plan.

It is our understanding that CMS provides a “hard” edit to each MAC that is supposed to catch & reject a claim when the beneficiary is enrolled in a Medicare Advantage plan. This edit was either not working, installed improperly or never installed. It should also be noted that this problem is not only affecting Rural Health Clinics previously serviced by Cahaba. This problem is also affecting other providers whose claims were processed by Cahaba.

If you are an RHC in the Palmetto service area, please be sure to visit the Palmetto website or sign up to be on the Palmetto listserv. This can be done by visiting the Palmetto website and click on the “listserv sign-up” icon.

P.S. – The 180 day timeframe referred to in the letter applies to the review of claims the RHC should undertake beyond the 4 years where there may be a patient obligation issue. Currently, Palmetto intends to commence recoupment of the claims they have identified based upon their 4-year look-back on July 15th unless the RHC files a request to review based upon credible information you have that Palmetto may have identified claims(s) in error.