This section provides information about the following topics regarding overpayments:
- Introduction to RDS Overpayments
- Timing for Satisfying Overpayments
- User Role Responsibilities for Satisfying an Overpayment
- Remittance Process
- Communication About Overpayments
- Send an Overpayment Remittance
- Offsetting an Overpayment With a Positive Payment Request on Another Application
- Consequences of Not Satisfying an Overpayment
Introduction to RDS Overpayments
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.
Review an Overpayment
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 cumulative 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.
Timing for Satisfying Overpayments
When the Reconciliation Determination for an application is made, CMS' RDS Center will send an Overpayment Notification Email stating that a balance is due. J.P. Morgan Chase (the RDS payment processor) will send a separate email invoice that includes a link to remit payment online.
Payment is due upon receipt of the J.P. Morgan Chase email containing the link to remit payment online.
User Role Responsibilities for Satisfying an Overpayment
CMS' RDS Center and J.P. Morgan Chase (the RDS payment processor) will send overpayment emails to the Plan Sponsor's Authorized Representative, Account Manager, and Designees with the Appeal privilege.
The Plan Sponsor is responsible for satisfying all overpayments that occur.
Remittance Process
When there’s an overpayment:
- RDS emails you an Overpayment Notification
- J.P. Morgan Chase (the RDS payment processor) emails you an invoice with:
- A summary of the overpayment
- A one-time payment link
- After you pay, J.P. Morgan Chase emails you a confirmation
- RDS emails you an Overpayment Notification of Reduction of Balance
To make a payment, you need:
- The Application ID associated with your overpayment for verification
- The valid one-time payment link from your email invoice
- A business or personal checking/savings account – credit or debit card payments are not accepted
- No additional registration required!
Communication About Overpayments
CMS' RDS Center and J.P. Morgan Chase (the RDS payment processor) will send overpayment emails to the Plan Sponsor's Authorized Representative, Account Manager, and Designees with Appeal privileges in the following scenarios:
- Overpayment Notification – informs the Plan Sponsor that an overpayment has occurred
- Invoice from J.P. Morgan Chase – contains a summary of the overpayment with a link to remit payment online
- Payment Confirmation from J.P. Morgan Chase – confirmation that J.P. Morgan Chase received the payment
- Overpayment Notification of Reduction of Balance – informs the Plan Sponsor of recent activity for an application including updated balance information resulting from receipt of an overpayment remittance via online payment, or offset from a positive payment request on another application with the same Plan Sponsor ID, when applicable
- Refund Notification - informs the Plan Sponsor of a refund
Note: Any requests for assistance regarding overpayments should be directed to CMS' RDS Center.
Send an Overpayment Remittance
Plan Sponsors must submit overpayment remittances electronically via the J.P. Morgan Chase payment portal. No other methods of payment will be accepted by CMS' RDS Center.
J.P. Morgan Chase will send an email invoice to the Plan Sponsor’s Authorized Representative, Account Manager, and Designees with Appeal privileges once the overpayment is determined. This email will contain a one-time payment link to remit payment online. Payment is due upon receipt of this email.
Plan Sponsors do not need a J.P. Morgan Chase account to submit payment, nor will registration with the bank be required to satisfy the overpayment. Plan Sponsors must provide the Application ID for verification during the payment process.
Overpayment Remittance Acknowledgement
CMS' RDS Center will send an Overpayment Notification of Reduction of Balance email to the Authorized Representative and Account Manager when the online payment is applied to the overpayment balance.
Offsetting an Overpayment with a Positive Payment Request on Another Application
If there are any positive payment requests on another application with the same Plan Sponsor ID when the Reconciliation Determination resulting in overpayment is made, CMS' RDS Center will automatically deduct the overpayment from these positive payment requests. The Plan Sponsor does not need to request an offset.
However, if there is no positive payment request on another application with the same Plan Sponsor ID, the Plan Sponsor must act to satisfy the overpayment through electronic payment.
When an offset occurs, CMS’ RDS Center will notify the Plan Sponsor via email. That notification email will communicate the remaining balance and, if applicable, confirm that the overpayment is fully satisfied.
Refunding Monies
If an overpayment is offset by a positive payment request on another application, and then an overpayment remittance is received, CMS' RDS Center will refund the monies. The refund payment will be satisfied by Electronic Funds Transfer (EFT) to the account specified on the application. A Refund Notification Email will be sent to the Authorized Representative, Account Manager, and Designee with the Appeal privileges to inform them that the monies have been returned.
Remit Payment Even if You Have Requested an Appeal
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.
Request a W-9 Form for Tax Purposes From CMS' RDS Center
Contact CMS' RDS Center to request a W-9 tax form.
CMS' EIN
The Centers for Medicare & Medicaid Services Employer Identification Number (EIN) is 52-0883104.
Consequences of Not Satisfying an Overpayment
Outstanding Overpayments
CMS reserves the right to refer outstanding amounts to the U.S. Department of Treasury for collection.
Assessing Interest on an Overpayment
CMS reserves the right to assess interest on outstanding overpayment amounts. In such cases, Plan Sponsors will be informed before interest is assessed and notified of the interest rate.