06/05/2026    David Freedman, DPM

Recouped Payments from CMS

I am concerned because I am continuously getting
letters from CMS saying that they are recouping
payments. At first it was just one or two here or
there and for amounts less than 50$ but now I am
receiving several of them a day and they are
really adding up! I asked my biller and she said,
"This issue is currently affecting all providers
who bill with POS 31 (Skilled Nursing Facility)
and POS 32 (Nursing Facility). Medicare keeps its
own records to determine a patient’s status, and
we bill using the POS Medicare has on file at the
time the claim is submitted. The problem is that
Medicare often updates patient status after claims
have already been processed and paid. For example,
a claim might be paid under POS 32 with a higher
reimbursement, but if Medicare later changes the
status to POS 31, they will take back the
difference. This results in the overpayment
letters you are receiving.

Unfortunately, this is a widespread Medicare issue
and is beyond our control. Our team has researched
this thoroughly, and there is currently no way to
prevent these retroactive adjustments." Is there
any recourse here?

PM News Subscriber

Response from Codinghelpline.com: The simple
answer is that there is likely little recourse.
Providers furnishing services in a nursing
facility are responsible for determining the
patient's correct status and billing the
appropriate Place of Service (POS)—either POS 31
(Skilled Nursing Facility) or POS 32 (Nursing
Facility).

CMS places responsibility on the billing provider
to report the correct POS. Because providers often
do not have direct access to a facility's SNF
census, best practice is to obtain and retain
documentation from the facility—such as a face
sheet, census report, or Part A status report—
confirming whether the patient was in a Medicare
Part A SNF stay on the date of service.

Medicare reimburses differently based on POS. The
OIG found that practitioners frequently billed POS
32 instead of POS 31 for patients who were
actually in a Part A SNF stay. Since POS 32 is
paid at a higher rate, this resulted in
significant Medicare overpayments. CMS
subsequently implemented edits and directed MACs
to identify and recoup these overpayments.

To reduce the risk of future recoupments,
providers should:

• Obtain a weekly or monthly census identifying
Part A residents.
• Verify each patient's status on the date of
service.
• Retain supporting facility documentation for
audit purposes.
• Bill POS 31 for Part A SNF residents and POS 32
for long-term care/non-Part A residents.

David Freedman, DPM, Silver Spring, MD

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