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Submitting a Rebuttal

Published 01/04/2021

Unlike the submission of an appeal subject to the limitation on recoupment, the submission of a rebuttal statement does not automatically stop recoupment while the request is under review. Further, the submission of a rebuttal statement does not guarantee recoupment will be stopped or delayed after a decision is reached. To stop the recoupment process, providers must submit a valid appeal via a redetermination request.

The rebuttal process allows the provider an opportunity to provide a statement and accompanying evidence indicating why the overpayment action will cause a financial hardship and should not take place. A rebuttal is not intended to review supporting medical documentation or disagreement with the overpayment decision. If you choose to submit a rebuttal statement, it must be sent to Palmetto GBA within 15 days from the date of the demand letter. Palmetto GBA will review the request and consider whether to proceed or discontinue with recoupment of the overpayment.

CMS Regulation References

Publication 100-06, Chapter 3, Section 200.1.2 (PDF, 594 KB)
Publication 100.06, Chapter 4, Section 90.2.B (PDF, 1.10 MB)

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