Requesting Immediate Offset

Published 01/04/2021

Providers can elect the immediate offset process for demanded overpayments to avoid making a payment by check and/or avoid the assessment of interest if the immediate offset satisfies the overpayment in full before aging 31 days from the initial demand. Offsets that are associated with an immediate offset are considered a voluntary repayment of a debt.

The immediate offset process allows providers the opportunity to request an immediate offset each time you receive a demanded overpayment or you can make a permanent request for all future demanded overpayments.

An immediate offset request will be processed as soon as possible; however, this request does not guarantee that interest will not accrue on the overpayment. To eliminate the risk of interest accruing, your request should be submitted as soon as possible after being notified of the debt as interest automatically accrues 31 days from the date of the initial demand letter. To ensure timely processing, your request must be received in writing no later than 16 days from the date of the initial demanded overpayment.

Please keep in mind that immediate offset requests can only be honored if there are pending payments in the Medicare claims processing system from which to recoup. If there is an insufficient amount of pending payments to satisfy the overpayment, interest may accrue. When there is a remaining principal balance after the initial immediate recoupment, we will continue the recoupment process and other collection activities until the debt is repaid. 

To request an immediate offset for a demanded debt, you must submit your request in writing. It may be submitted using U.S. mail, by fax or by email with an encrypted file. Providers are encouraged to submit the immediate offset form via Palmetto GBAs eServices. Providers can electronically submit an eOffset request and PDF attachments online. Once submitted, you will receive a confirmation from Palmetto GBA indicating that the request has been received. For more information, please review the Financial Tools Section in the
eServices User Manual (PDF, 8.25 MB).

Written Requests
Your written request must include each of the following data elements:

  1. Provider name and contact phone number
  2. Provider's Medicare number and/or National Provider Identification (NPI)
  3. Provider's administrator or CFO's signature (someone with authority is required to sign)
  4. Copy of the first page of your demand letter or the letter number from the first page of the demand letter
  5. Which option the provider is requesting
    • A one-time request on the total overpayment amount (all accounts receivables) in a single demand letter and any future demanded overpayments; or
    • A request on the demanded overpayment (all accounts receivables) addressed in a single demand letter only

To ensure your request for immediate offset has all of the five required data elements so that it does not have to be rejected based on missing information, we recommend you submit your request using the Immediate Offset request form (please see the links to the form below). 

You can choose to stop participating in the immediate offset process at any time by submitting a written request. Please keep in mind that by requesting an immediate offset, you are waiving the potential receipt of 935 interest pursuant to Section 1893(f)(2). Such interest may be payable for certain overpayments reversed at the Administrative Law Judge (ALJ) level or subsequent levels of appeal.

The Immediate Offset option is not available for voluntary/self-disclosed overpayments. The immediate offset option is only for overpayments that generate a demand letter. 

Link to Refund Form

Centers for Medicare & Medicaid Service (CMS) Regulation References

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