Section title: Requests for Interpretation
Interest owed to payer

Our provider is being charged with an interest penalty for not refunding an overpmt timely to the requirement in the refund letter. How should the penalty show in the 835?

The overpmt is being withheld using WO and the penalty is in E3. The E3 is also being used to withhold other types of FB and CS advances. This causes a reconciling issue with automated posting.

l% section 2.2.9 states positive or negative amount can be used.

RFI Response

The 5010 TR3 does not currently have a specific code to support this penalty process.

RFI Recommendation

It is the recommendation to follow the existing 835 TR3 section option 1 - recoup the overpayment immediatly and this would eliminate the penalty issue.

The E3 qualifier is specific to capitation reporting and not intended for penalty interest.

A workaround would be to use the WO adjustment reason code with INT added to the reference identification to help signal to the provider that this is the interest associated with the recovery.