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US healthcare · Back-end revenue cycle

Payment Posting, Reconciliation and Credit Balances

A claim is not finished when the payer decides it. It is finished when every dollar the payer sent, every dollar it took back, and every dollar the patient paid is recorded on the right account, agrees with the bank, and leaves a balance that is zero or correctly owed by someone. This tutorial covers the 835 remittance in depth, electronic funds transfer and the CAQH CORE operating rules, posting and takebacks, cash reconciliation and month-end close, credit balances and refunds, the Medicare 60-day overpayment rule as amended in 2025, and unclaimed property.

Receive835 / EFT

What did we get, and for what?

The 835 explains the payment claim by claim; the EFT is the money. They must be matched.

The TRN trace number is the thread that ties the deposit to the remittance.

PostCLP / CAS / PLB

Does every account tell the truth?

Payments, contractual adjustments, patient responsibility, denials and recoupments, each on the right account.

Auto-posting handles the routine; the exceptions are where cash is lost or misstated.

BalanceBank / ledger

Does the book agree with the bank?

Remit totals, deposits and posted amounts must reconcile daily and close monthly.

Credit balances are liabilities with deadlines: refund, offset, report or escheat.

14 chapters4 interactive toolsFigures verified Oct 2026
Chapter 01

The big picture

Payment posting is the step where adjudication results become accounting entries. Reconciliation is the discipline of proving that those entries agree with what the bank received. Credit balance management is what happens when the entries show that someone paid too much. Together they are the last mile of the revenue cycle, and the part most often audited.

Everything upstream (eligibility, authorization, coding, claim submission) exists to produce a payment. Posting is where that payment is recognized, where the difference between billed and paid is explained and classified, where the patient's remaining balance is set, and where a denial is turned into a work item instead of a silent write-off. Done well, posting is same-day, mostly automated, and balanced to the penny. Done badly, it produces phantom A/R, unapplied cash that nobody owns, statements to patients who owe nothing, and overpayments that quietly become compliance liabilities.

The two transactions at the center of this chapter are the X12 835 (the electronic remittance advice, or ERA) and the ACH CCD+ electronic funds transfer (EFT). The 835 says what was paid and why; the EFT moves the money. HIPAA requires health plans to offer both as standard transactions, and the CAQH CORE operating rules require that they be matchable to each other within a defined window.

Why it matters in numbers

Adoption

78% EFT, 89% ERA

Share of medical claim payments made by EFT in 2024 (2025 CAQH Index, now published as the DataSpring Index) and share of medical remittances delivered as a fully electronic 835 (2024 CAQH Index). Roughly one payment in five still arrives as a paper check or a virtual card, and each manual remittance costs a provider about $2.72 more to work than an electronic one.

Cost of holding money

11.875%

Annual interest rate on Medicare overpayment debts more than 30 days old, for the quarter beginning July 21, 2026 (the rate is reset quarterly; check the current MAC notice). An identified overpayment that is not reported and returned on time is also a potential False Claims Act liability at $14,308 to $28,619 per claim, plus treble damages.

Fees on your own money

Up to 5%

Fees charged on virtual credit card payments reported by the AMA and MGMA to CMS. CMS has stated that a health plan cannot require a provider to accept virtual card payments and must honor a request for the HIPAA EFT standard, for which the only legitimate charge is the provider's own bank fee.

Who is involved

Payment poster / cash applications
Applies 835s, paper EOBs, patient payments and adjustments to accounts. Works the exception queue where auto-posting could not match or balance.
Treasury and bank
Receives ACH deposits, lockbox checks and card settlements; provides the bank statement and the CCD+ addenda records that carry the TRN.
Clearinghouse or ERA vendor
Receives 835 files from payers, normalizes them, and delivers them to the practice management (PM) system. Often also the EFT enrollment intermediary.
Payer
Adjudicates the claim, sends the 835, initiates the EFT, and later may recoup, reverse or reprocess, each of which appears on a future 835.
Finance and general ledger (GL)
Books cash, contractual allowances, bad debt and refunds; owns the month-end close and the reconciliation of PM cash to the GL and bank.
Denials and A/R follow-up
Receives the zero-pay and partial-pay claims that posting routes to them, with the CARC and RARC codes intact.
Compliance
Owns the overpayment policy: how credits are identified, investigated, refunded and, for Medicare, reported and returned within the statutory deadline.
Patient
Pays copays, deductibles and statements; is owed a prompt refund when they overpay, and is the most common "owner" of unclaimed property a provider holds.

What goes wrong

Cash that never lands

An 835 arrives with no EFT, or an EFT with no 835. Without reassociation, the money sits in a suspense account and the claims age as if unpaid.

Denials disguised as adjustments

Auto-posting rules that write off every CO code treat a CO-197 denial like a CO-45 contractual allowance. The denial is never worked, and the write-off is invisible.

Takebacks posted wrong

A PLB recoupment reduces the check but is not posted to the original claim, so the account shows paid while the bank shows less. The variance surfaces months later.

Phantom patient balances

Secondary payments posted after the statement went out, or a copay collected at the desk but posted as a payer payment. Patients are billed for money already received.

Credit balances that age

Overpayments nobody researches. They understate A/R, they are owed to someone, and for Medicare they become reportable overpayments with a 60-day clock.

Unapplied cash

Payments posted to a holding account because the claim could not be found. Revenue is recognized late, follow-up works accounts that are already paid, and statements go out wrong.

Chapter 02

How money arrives

Payments reach a provider through several channels, each with its own remittance format, its own timing, and its own ways to go wrong. The posting process must handle all of them and bring them to one balanced picture.

ChannelThe moneyThe explanationMatching keyWatch for
EFT + ERA (the HIPAA standard pair)ACH CCD+ credit to the provider's bank accountX12 835 delivered by the payer or through a clearinghouseTRN trace number in the CCD+ addenda and in the 835 TRN segmentTiming gap between EFT and 835; multiple 835s under one EFT; payer-side enrollment errors sending money to an old account
Paper check + paper EOBCheck mailed to the office or to a bank lockboxPaper explanation of benefits, often also available as a PDF on the payer portalCheck number and payer claim numberManual keying errors; lockbox images that cut off the EOB; checks held in a drawer and deposited late
Check + 835Paper check (BPR04 = CHK)835 with the check number in TRN02TRN02 = check numberPosting the 835 before the check clears; voided or reissued checks appearing as PLB adjustments
Virtual credit card (VCC)A single-use card number faxed or emailed; the office keys it into its card terminalSeparate remittance, often a PDF, sometimes an 835 with BPR04 = NONCard payment referenceMerchant fees of up to 5% deducted from the payment; the deposit never equals the remittance; the provider can refuse VCC and demand EFT
Patient paymentsCard, cash, check, portal, payment plan, HSA cardReceipt, statement reference, portal transaction IDGuarantor account and encounterCopays posted to the wrong encounter; plan installments posted as lump sums; cash control at the front desk
Capitation and other non-claim paymentsMonthly ACH or checkMembership roster; PLB entries on an 835 (CT capitation payment, IP incentive premium)Contract and monthMust not be posted to patient accounts; belongs in GL revenue for the contract
Settlements, interest, recoupmentsNetted inside an EFTPLB segment on the 835 (L6 interest, WO recoupment, LS lump sum)PLB03-2 reference, usually the payer claim numberThese change the check total without being claim payments; they need their own posting rules

The posting cycle, end to end

  1. 1

    Receive Daily

    Pull 835 files from the clearinghouse, lockbox images from the bank, card settlement reports, and front-desk batches. Log each one with its source, date and control total before anyone touches it.

  2. 2

    Reassociate Same day

    Match each 835 to its EFT by TRN, each paper EOB to its check, each card settlement to its merchant report. Anything unmatched goes to a suspense list with an owner and a date, not into the posting queue.

  3. 3

    Post Within 24–48 hours of receipt

    Auto-post the 835 line by line: payment, contractual adjustment, patient responsibility, denial reason. Route exceptions (unmatched claims, out-of-balance lines, zero pays, takebacks) to a work queue instead of forcing them.

  4. 4

    Classify During posting

    Separate contractual adjustments (expected, write off) from non-contractual ones (denials, bundling, timely filing: work or appeal before any write-off). Transfer patient responsibility to the guarantor or to the secondary payer.

  5. 5

    Balance the batch Before close of day

    Posted payments plus posted PLB entries must equal BPR02 on the 835, which must equal the bank deposit. Variances are explained or the batch is not closed.

  6. 6

    Reconcile and close Daily and monthly

    PM cash to bank; PM adjustments to GL contractual allowance; refunds issued to credit balances cleared. Month-end: every deposit tied to a posting batch, every credit balance aged and owned.

Terms you need before reading an 835

Billed charge
What the claim asked for (CLM02 on the 837, CLP03 on the 835, SVC02 per line).
Allowed amount
The contract or fee-schedule price the payer recognizes. The 835 shows it in AMT*B6 at the line level. Cost sharing is calculated on it.
Contractual adjustment
Billed minus allowed, written off because the contract says so. Group code CO, usually CARC 45.
Patient responsibility
Deductible, coinsurance and copay (group code PR with CARC 1, 2, 3), plus non-covered amounts the patient agreed to.
Paid amount
Allowed minus patient responsibility minus any payer-side reductions (sequestration, interest withholding, prior-payer paid).
Provider-level adjustment
A change to the check that is not tied to a single claim line: recoupments, interest, forwarding balances. The PLB segment.
Balancing
The rule that every 835 obeys: charge = paid + adjustments on each line and claim, and total payment = claim payments minus provider-level adjustments.
The one equation to memorize

BPR02 = Σ CLP04 − Σ PLB04. The amount of the payment equals the sum of all claim-level paid amounts minus the sum of all provider-level adjustments, where a positive PLB amount reduces the payment and a negative one increases it. If your posting batch does not reproduce BPR02, you have not finished posting.

Chapter 03

Reading an 835

The 835 (ASC X12N 005010X221A1) is the HIPAA standard for the health care claim payment and remittance advice. It is one file per payment, and it is built in three layers: the header that describes the money, the claim loops that explain it, and the trailer that adjusts it.

The structure

LayerSegmentsWhat it carriesPosting use
HeaderST, BPR, TRN, CUR, REF, DTMPayment method and amount (BPR), the reassociation trace number (TRN), production date (DTM*405)Reassociate to the EFT; set the batch control total; decide whether a payment accompanies the file (BPR01)
Payer and payeeN1*PR, N3, N4, REF*2U, PER; N1*PE, REF*TJWho paid (payer ID in REF*2U) and who is paid (NPI in N1*PE, tax ID in REF*TJ)Route to the right billing entity when one tax ID has several NPIs
Claim loop (2100)LX, TS3/TS2, CLP, CAS, NM1, MIA/MOA, REF, DTP, AMT, QTYOne CLP per claim: status, billed, paid, patient responsibility, payer claim number; claim-level adjustments; patient, insured, rendering provider; Medicare inpatient (MIA) and outpatient (MOA) detailsFind the account by CLP01 (your patient control number); post claim-level amounts
Service loop (2110)SVC, DTP, CAS, REF, AMT, QTY, LQOne SVC per line: procedure, charge, paid, units; line-level adjustments (CAS); allowed amount (AMT*B6); remark codes (LQ*HE)Post line by line so contractual, patient and denial amounts land on the right charge
TrailerPLB, SEProvider-level adjustments that change the check without touching a claim; segment countPost recoupments to the referenced claims, interest to non-patient revenue; balance the batch

A fictional 835 from Northwind Health Plan

Below is a simplified, fictional 835 covering two claims from Riverside Medical Group: Jordan Doe's office visit and MRI (paid), and a therapy claim for another patient (denied for no authorization), followed by a recoupment and an interest payment in the PLB. Select any line to see what it means. Envelope segments (ISA, GS, GE, IEA) are omitted.

Sample 835 · Northwind Health Plan → Riverside Medical Group · EFT $468.42

    Amounts are illustrative. Real files carry more segments per claim (claim received date, group number, MOA for Medicare, REF*6R line control numbers) and many claims per file.

    The segments that decide the posting

    BPR

    Financial information

    BPR01 tells you whether money is coming: I remittance only (payment sent separately by EFT), C payment accompanies the remittance (a check), H notification only (no payment, such as a zero-pay remit), D debit. BPR02 is the amount. BPR04 is the method: ACH, CHK, NON (no payment), FWT (wire). BPR16 is the effective entry date, the date the ACH credit is scheduled to settle.

    TRN

    Reassociation trace number

    TRN01 = 1 (current transaction trace). TRN02 is the trace number the payer also places in the CCD+ addenda record, or the check number for paper. TRN03 is "1" followed by the payer's nine-digit tax ID. The pair TRN02 + TRN03 is unique and is the key that links money to explanation.

    CLP

    Claim payment information

    CLP01 your patient control number (echoed from CLM01). CLP02 claim status: 1 processed as primary, 2 secondary, 3 tertiary, 4 denied, 19/20/21 processed and forwarded to another payer (crossover), 22 reversal of a previous payment, 23 not our claim, forwarded. CLP03 billed, CLP04 paid, CLP05 patient responsibility, CLP06 claim filing indicator (12 PPO, MB Medicare Part B, MC Medicaid, HM HMO, CI commercial), CLP07 the payer's claim number (ICN) you will need for appeals and corrected claims.

    CAS

    Claim and line adjustments

    CAS01 group code: CO contractual obligation (provider write-off, not billable to patient), PR patient responsibility, OA other adjustment (neither; often the prior payer's payment, CARC 23), PI payer-initiated reduction. Then up to six triplets of CARC, amount and optional quantity. Every CAS amount is money that explains part of the gap between charge and payment.

    SVC

    Service line

    SVC01 procedure code with modifiers (HC:99214:25), SVC02 line charge, SVC03 line paid, SVC04 revenue code (institutional), SVC05 units paid. If the payer re-coded the line, SVC06 carries the original code. Lines balance independently: SVC02 = SVC03 + line CAS amounts.

    AMT / LQ

    Allowed amount and remark codes

    AMT*B6 is the allowed amount at the line level (AMT*AU, coverage amount, at the claim level). LQ*HE carries remittance advice remark codes (RARCs) that refine the reason: N-, M- and MA-prefixed codes. A CARC 16 (missing information) means nothing without its RARC.

    PLB

    Provider-level adjustment

    PLB01 provider NPI, PLB02 the fiscal period end date, then pairs of a reason code with a reference (PLB03) and an amount (PLB04), up to six pairs. Positive amounts reduce the payment; negative amounts increase it. Chapter 06 covers the codes.

    MIA / MOA

    Medicare inpatient and outpatient adjudication

    Medicare 835s carry DRG amounts, outlier and capital amounts (MIA) or the reimbursement rate and HCPCS payable amount (MOA), plus remark codes in MIA05 and MOA03 through MOA07. Institutional posting uses these to reconcile to expected DRG and APC payment.

    Balancing, line by line

    LevelRuleExample from the sample
    Service lineSVC02 charge = SVC03 paid + Σ line CAS amounts$1,800 = $440 + $850 (CO-45) + $400 (PR-1) + $110 (PR-2)
    ClaimCLP03 charge = CLP04 paid + Σ claim CAS + Σ line CAS; CLP05 = Σ PR amounts$2,150 = $590 + $1,020 (CO) + $540 (PR)
    TransactionBPR02 = Σ CLP04 − Σ PLB04$468.42 = ($590 + $0) − ($125.00 − $3.42)
    Sequestration and other payer-side reductions

    Medicare claims carry a 2% reduction as CO-253 (sequestration) on the paid amount; it is a contractual adjustment, not patient responsibility, and the 2% cut under the Budget Control Act remains in effect in 2026 (the additional 4% statutory PAYGO sequester that could have started in January 2026 was waived in November 2025). Interest the payer owes you for late payment appears as a positive AMT*I at the claim level and as PLB L6 at the provider level, and it must be posted as interest income, never as a claim payment.

    Chapter 04

    EFT, ERA and the CAQH CORE operating rules

    Since January 1, 2014, HIPAA has required health plans to support a standard EFT (NACHA CCD+ with the X12 835 TRN segment in the addenda record) and a standard ERA (the 005010X221A1 835), and to follow the CAQH CORE operating rules that make the two reassociable. Knowing the rules tells you what you may demand from a payer.

    The Phase III operating rules

    RuleNameWhat it requiresWhat it means for posting
    CORE 350835 infrastructureConnectivity, batch acknowledgments, and companion guide format for the 835Your clearinghouse should acknowledge every file; a missing 835 is detectable
    CORE 360Uniform use of CARCs and RARCsPayers must use CORE-defined code combinations for four common business scenarios (additional information required, missing or invalid data, billed service not covered, benefit for billed service not separately payable) so the same denial reads the same way across payersAuto-posting rules can key on code combinations rather than payer-specific habits
    CORE 370EFT and ERA reassociationThe health plan must put the same TRN in the CCD+ addenda and the 835, and must release the 835 no sooner than three business days before and no later than three business days after the CCD+ effective entry date; plans must audit that 90% of transactions each month meet the window, and must publish late or missing EFT/ERA resolution proceduresIf the 835 and the money are more than three business days apart, the payer is out of compliance; use its published resolution procedure, then complain to CMS
    CORE 380EFT enrollment dataA maximum standard set of about 70 data elements for EFT enrollment, offered electronically, with a defined templateEnrollment paperwork should look the same across payers; refuse non-standard demands
    CORE 382ERA enrollment dataAbout 65 standard elements for ERA enrollment, also offered electronicallyEnroll for ERA and EFT together, and update both when a bank account or clearinghouse changes

    Reassociation in practice

    1. 1

      Payer initiates the ACH credit Stage 1

      The payer's bank sends a CCD+ entry with one addenda record. Field 3 of the addenda carries the 835 TRN segment: TRN*1*20261022NWH0001234*1999999999. The effective entry date is the settlement date.

    2. 2

      Payer releases the 835 Within ±3 business days

      The 835 carries the identical TRN02 and TRN03, BPR16 equal to the effective entry date, and BPR02 equal to the ACH amount.

    3. 3

      Bank reports the deposit Stage 3

      HIPAA does not require your bank to pass the addenda record on to you. Arrange it: ask for the CCD+ addenda in your bank reporting (most banks offer it as an EDI or BAI2 report). Without it, you are matching on amount and date alone.

    4. 4

      You match and post Same day

      The PM system or clearinghouse pairs TRN to deposit. A match releases the 835 for posting; the control total is BPR02. An unmatched 835 or deposit opens a research item.

    5. 5

      Late or missing After 4 business days

      CMS describes an EFT or ERA as late or missing once four business days have passed after receipt of the other. Follow the plan's written resolution procedure, which it must have given you at enrollment.

    Virtual credit cards and fees

    What CMS has said

    In its HIPAA administrative simplification FAQs, CMS stated that a health plan cannot require a provider to accept virtual credit card payments, that a provider may request the standard EFT and the plan must comply, and that the only fee that may attach to a standard EFT is the provider's own bank charge (CMS cited an average of 34 cents per transaction). Plans and their vendors may not charge for "value-added" services the provider did not ask for, nor for normal telecommunications. Non-compliance can be reported through the CMS administrative simplification complaint process.

    Practical defense
    • Opt out in writing. Tell every payer and payment vendor that you elect the HIPAA EFT standard and decline VCC. Keep the letters.
    • Watch the deposit. A VCC payment arrives net of the merchant fee. The remittance says $1,000; the settlement says $970. Post the remittance in full and book the fee where you can see it.
    • Read the enrollment. Some payment vendors enroll you in EFT "with fees" (1.5% to 2% has been reported). The no-fee CCD+ is your right; ask for it by name.
    • Count it. Monthly: payments received by VCC, fee dollars lost, payers responsible. The number usually ends the debate about whether enrollment effort is worth it.

    Enrollment hygiene

    Chapter 05

    Posting payments and adjustments

    Posting is applying each amount on a remittance to the right account, the right encounter and the right charge line, with the right transaction type. The transaction type matters as much as the amount: a dollar posted as a contractual adjustment disappears; the same dollar posted as a denial becomes work.

    Auto-posting: what the rules should do

    835 elementAuto-post actionException trigger
    CLP01 → accountFind the encounter by your patient control number; confirm the patient name and date of serviceNo match, or more than one match: route to unapplied queue with the payer claim number
    CLP04 paidPost as insurance payment from the payer in N1*PR, dated the EFT effective datePayment exceeds charge or exceeds expected allowed by more than tolerance: potential overpayment
    CAS*CO*45 (and other contractual CARCs the contract defines)Post as contractual adjustment against the lineAdjustment larger than expected under the loaded contract: underpayment review
    CAS*PR*1, 2, 3Transfer deductible, coinsurance, copay to patient responsibility, or to the secondary payer if one is on filePR amount with no patient or secondary on file; PR on a Medicaid or QMB patient (billing prohibited)
    CAS*CO with denial CARCs (4, 11, 16, 18, 22, 29, 50, 96, 97, 109, 119, 197, 198, 204)Post as a denial adjustment with the CARC and RARC, leaving the balance open, and route to the denial queueNever auto-write-off. A rule that writes off every CO code is the most expensive rule in the system
    CAS*OA*23Record the prior payer's payment impact on a secondary remit; no write-offSecondary paid more than the primary's patient responsibility: credit balance check
    CAS*CO*253Post sequestration as a contractual adjustmentNone; but it belongs in its own adjustment code for reporting
    CLP02 = 4 (denied)Zero-pay claim: post the CAS codes, keep the balance open, route by CARCAlways an exception when CARC is 16, 18, 22, 29, 197, 198 or 204
    CLP02 = 22 (reversal)Reverse the earlier payment and adjustments on that claim; expect a corrected CLP in the same fileNo corrected claim follows: the payer took the money back; open the account
    CLP02 = 19, 20, 21 (forwarded)Post as primary and mark the secondary claim as crossed over; do not bill the secondary separatelyNo secondary remittance within the expected window
    AMT*I, PLB L6Post interest to a non-patient interest income accountInterest posted to a patient account creates a false credit
    PLB WO, FB, 72, CSPost to the referenced claim per chapter 06 rulesNo reference: hold in a provider-level suspense account until identified

    Contractual versus non-contractual

    Contractual adjustments

    Expected, by contract

    The difference between the charge and the allowed amount under a fee schedule, DRG, APC or per diem (CARC 45), sequestration (253), and payer-defined bundling that the contract accepts. These are written off at posting. They should reconcile to the expected contractual allowance the contract-modeling system predicts; a variance is an underpayment or an overpayment, not an adjustment.

    Non-contractual adjustments

    Avoidable, by someone

    Denials (no authorization, not covered, timely filing, medical necessity, duplicate, missing information), bundling edits that a modifier would have cleared, non-covered services that an ABN would have shifted to the patient, and balances written off because follow-up ran out of time. These go into the denial and write-off inventory with a reason code, an owner, and an approval threshold. They are the measure of revenue leakage.

    Patient responsibility

    Transferred, not adjusted

    PR amounts move the balance to the guarantor (or to the secondary payer) with the deductible, coinsurance and copay split preserved, because statements and payment plans explain them to the patient. A copay already collected at check-in must be matched here so the statement is net.

    Small-balance and administrative write-offs

    Policy, not habit

    Balances under a threshold (often a few dollars), courtesy adjustments, prompt-pay discounts and financial assistance each need a distinct adjustment code and an approval level. Auto-writing small balances is fine when the policy is written down and applied to debits and credits alike.

    Zero-pay remittances

    A zero-pay 835 (BPR01 = H or BPR02 = 0) is still a remittance. It may carry denials, reversals, claims applied entirely to the deductible, or payments offset entirely by a recoupment. Each case posts differently:

    What the 835 showsWhat it meansPosting
    CLP02 = 4, CAS*CO*197Denied, no authorizationDenial adjustment code, balance open, denial queue; patient not billable in network
    CLP02 = 1, CLP04 = 0, CAS*PR*1 for the full allowedProcessed, applied to deductibleContractual for charge minus allowed; transfer the allowed to the patient (or secondary)
    CLP02 = 1, CLP04 > 0, PLB WO equal to the sumPaid, but the whole check was taken for a prior overpaymentPost the claim payments normally and the recoupment to the referenced claims; the net deposit is zero
    CLP02 = 22 with negative amounts, no replacementReversal only; the payer withdrew the earlier adjudicationReverse the earlier posting; expect a recoupment or a reprocessed claim later; open the account
    CLP02 = 1, CAS*CO*96 with RARC N130 and CAS*PR for the same amountNot covered; patient responsibility per plan termsTransfer to patient only if the plan says PR; CO means the provider absorbs it

    Paper EOBs and the lockbox

    Lockbox

    Let the bank open the mail

    A bank lockbox receives checks and EOBs, deposits the checks the same day, and sends you images and a data file. Advantages: faster cash, an audit trail, no checks in desks. Requirements: the EOB images must be complete and legible, the deposit file must carry the check number, and your posting system must be able to key paper EOBs against the deposit total.

    Manual posting

    Key it like an 835

    Posting from paper should produce the same transactions as auto-posting: payment, contractual adjustment with CARC, patient responsibility with its split, denial with its reason. Posters who key "adjustment" for everything destroy the denial data. Many payers now post the same EOB as a PDF on the portal, and some will convert paper to 835 on request.

    Convert the paper

    Every paper payer is an enrollment task

    List the payers still paying by check and EOB, ranked by volume and dollars. Each one is an ERA and EFT enrollment to pursue. The CAQH Index estimates the provider's cost of a manual remittance at $5.67 against $2.95 for an electronic one, before counting the posting errors and float.

    Control totals

    Batch, count, balance

    Every manual batch has a header: source, date, number of checks, total dollars. The posted total must equal the deposit total before the batch closes. Unmatched remainders go to unapplied with the check number, never to a random account.

    Patient payments and payment plans

    Point-of-service payments
    Copays and pre-service deposits are posted to the specific encounter at the time of collection, not held in a batch. A receipt with the encounter and the amount prevents the "I already paid that" call.
    Statements and portal payments
    Payments against a statement should apply to the oldest open patient balance first unless the patient directs otherwise, and should never apply to a balance that still has an open insurance claim.
    Payment plans
    A plan is a schedule, not a transaction. Each installment posts when it is received; the plan record tracks the remaining commitment. Missed installments trigger a defined contact sequence before any collection step.
    Prepayments and deposits
    Money taken before the service is a liability until the claim adjudicates. Post it to the encounter as a patient payment, then let the adjudicated patient responsibility consume it. A deposit larger than the final responsibility is a credit balance from day one.
    Card processing
    Card settlements arrive net of fees in some setups and gross in others. Decide which, and reconcile the merchant statement to posted patient payments monthly.
    Refund of a patient payment
    When a patient paid at the desk and the payer later covers the service in full, the credit belongs to the patient. Most organizations refund within 30 days of identification; some states set a deadline.
    Posting discipline
    • Post from the remittance, not from the deposit. The remittance explains the money; the deposit confirms it. Posting from a deposit slip creates unexplained adjustments.
    • Keep the codes. Every adjustment carries its group code, CARC and RARC. Denial analytics, contract variance reports and appeal letters all depend on them.
    • Date it right. Payment date is the EFT effective date or the check deposit date. Posting date is separate. Month-end cut-off depends on both.
    • No forced balancing. If a line does not balance, the file is wrong or the contract is wrong. Research it; do not plug it.
    • Separate duties. The person who posts should not also issue refunds or approve write-offs above a threshold. Cash handling, posting and reconciliation are three roles.
    Chapter 06

    Takebacks, reversals and PLB codes

    Payers change their minds. A reprocessed claim, an audit finding, a coordination-of-benefits discovery or a duplicate payment all end the same way: money is taken back. On the 835 that happens in two places, the claim loop (reversal and correction) and the PLB segment (provider-level adjustment). Reading both correctly is the difference between accounts that show reality and accounts that show a payment the bank never kept.

    Two ways a payer takes money back

    Reversal and correction

    CLP02 = 22, then a new CLP

    The payer sends the original claim again with status 22 and every amount negated (charge −$1,800, paid −$440, adjustments reversed), then a second CLP for the same claim with the corrected adjudication. The net of the two is the change. If the corrected claim pays less, the file's total goes down by the difference, and the deposit is smaller. If the payer is not ready to recoup, it offsets the difference with a negative PLB FB (forwarding balance) so the deposit is unchanged, and takes it on a later remittance with a positive FB or WO.

    Provider-level recoupment

    PLB WO

    No claim loop at all. The PLB carries reason code WO (overpayment recovery), a reference that usually contains the payer claim number or your patient control number, and a positive amount that reduces the deposit. The original claim on your books still shows the full payment, so you must post the recoupment against it yourself, re-opening the balance if the recoupment was wrong.

    PLB reason codes you will see

    CodeNameUsual signWhat happenedPosting
    WOOverpayment recoveryPositive (reduces the check)The payer recouped a prior overpayment on the referenced claim. A negative WO reverses or offsets an earlier recoupment, or pairs with a 72 when you sent a refund checkPost a negative payment to the referenced claim; if the account is now open, work it; if the recoupment is disputed, appeal within the payer's window
    FBForwarding balanceNegative now, positive laterA negative FB offsets a net-negative claim in this file so the check is not reduced yet; a positive FB on a later file collects itNegative FB: record a payer receivable for the deferred takeback; positive FB: clear it. Never post FB to a patient account
    L6Interest owedNegative (increases the check)Interest the payer owes for late payment (prompt-pay interest), often the sum of claim-level AMT*I amountsInterest income, non-patient. Not revenue on any claim
    72Authorized returnNegative, paired with a positive WOThe payer acknowledges a refund check you sent or a voided check; the pair nets to zeroNo posting if the refund was already posted when issued; otherwise post the refund and the recovery together
    CSAdjustmentEitherCatch-all: a reissued payment for a lost check, a correction to a prior PLB, a write-down of an FB balance, Medicare pass-through itemsRead the reference and the payer's description; hold in provider-level suspense until identified
    50Late chargePositiveMedicare: penalty for a late cost reportExpense, not a patient account
    51Interest penalty chargePositiveInterest charged to the provider on an overpayment debtInterest expense
    IRInternal Revenue Service withholdingPositiveBackup withholding sent to the IRS, usually a missing or mismatched W-9Tax receivable; fix the W-9 with the payer immediately
    LSLump sumNegativeBonus or settlement payments: quality program payments, Medicare pass-throughs such as indirect medical educationContract or program revenue in the GL
    PIPeriodic interim paymentNegativeMedicare PIP payments to hospitals on a schedule rather than per claimGL, reconciled at cost report settlement
    BDBad debt adjustmentNegativeMedicare bad debt reimbursementGL
    CT / IPCapitation payment / incentive premiumNegativeMonthly capitation or incentive payments carried on an 835Contract revenue; never a patient account
    AHOrigination feePositiveA fee deducted from the paymentExpense; challenge it if it is an EFT fee the payer may not charge
    WUUnspecified recoveryPositiveA recoupment the payer did not tie to a claimSuspense; demand the claim detail
    PLB and takeback posterPick the code and enter the PLB amount as it appears on the 835 (positive reduces the payment, negative increases it) to see the effect on the deposit and the posting actions.

    Handling a takeback end to end

    1. 1

      Identify the claim At posting

      Use PLB03-2 (payer claim number, patient control number, or both), the payer's recoupment letter, or the portal. A WU or unreferenced CS with no detail is a research item, and the payer owes you the detail.

    2. 2

      Validate the reason Before accepting

      Was the original payment actually wrong? Duplicate, COB (another payer was primary), audit finding, retroactive eligibility termination, corrected claim you sent. Many takebacks are correct; some are not, and the dispute window is short (often 30 to 90 days from the notice).

    3. 3

      Check the lookback Commercial and Medicaid plans

      Many states limit how far back a fully insured plan may recoup, commonly 12 to 24 months (Ohio moved from 24 to 12 months in 2025), with exceptions for fraud and COB. Self-funded ERISA plans generally claim exemption. Medicare's own lookback for provider self-reporting is six years.

    4. 4

      Post it Same batch

      Negative payment on the original claim, dated the recoupment, with the reason. If the payer reprocessed and paid a new amount, post that too. The account balance is now what the payer says you are owed; if you disagree, the balance is in dispute, not written off.

    5. 5

      Rebill the right party Within timely filing

      If the takeback was for COB, bill the correct primary (timely filing for the new payer often runs from the recoupment date, but confirm). If it was for eligibility, the patient may be liable; if it was a payer error, appeal.

    6. 6

      Close the loop Month-end

      Recoupments posted must equal PLB WO and positive FB totals for the month. Unposted recoupments are the most common cause of "cash posted exceeds cash received."

    Medicare recoupment timeline

    When a Medicare contractor demands an overpayment, the clock is fixed by regulation (42 CFR 405.370 to 405.379): a rebuttal may be filed within 15 days of the demand letter (it does not stop recoupment); interest accrues from day 31 if the debt is unpaid; recoupment from future payments begins on day 41; a redetermination request filed by day 30 stops recoupment while the first two appeal levels run (the limitation on recoupment under MMA section 935), and the last day to request redetermination at all is day 120. Interest, at the published quarterly rate (11.875% for the quarter from July 21, 2026), keeps accruing on a debt that loses on appeal. An extended repayment schedule can be requested when immediate repayment is a hardship.

    Chapter 07

    Reconciliation and month-end close

    Reconciliation proves three things agree: what the remittances say was paid, what the bank says was deposited, and what the PM system says was posted. When all three match, cash is complete and A/R is honest. When they do not, the difference is a finding with a cause, an owner and a deadline.

    The three-way match

    Remittance

    BPR02 on each 835, check amount on each EOB

    The control total for a posting batch. Internally, BPR02 must equal Σ CLP04 − Σ PLB04; if it does not, the file is corrupt or truncated and should be re-requested, not posted.

    Bank

    Deposit per the bank statement or CCD+ report

    One ACH credit per EFT, matched by TRN; lockbox deposits by batch; card settlements by day. A deposit that matches no remittance is unidentified cash and is still revenue someone will ask about.

    Ledger

    Posted in the PM system and booked in the GL

    Payments posted to accounts plus provider-level items posted outside accounts must equal the remittance total. The GL cash entry equals the bank deposit; the difference between the two is an in-transit or suspense item with a date.

    Remit-to-deposit reconciliation calculatorEnter the totals for one 835 and its deposit. The tool checks the file's internal balance, the bank match and the posting match, and suggests the usual cause of each variance.

    Unapplied and unidentified cash

    Unapplied

    We know who paid; we do not know for what

    A payer payment whose CLP01 matches no encounter (claim sent from another system, account number changed, a corrected claim with a new control number), or a patient payment with no statement reference. Post it to the payer's or guarantor's unapplied account the same day, then research with the payer claim number, the patient name and the date of service. Target: cleared within 30 days, with a weekly aging report.

    Unidentified

    We do not even know who paid

    A deposit with no remittance, no TRN match, and no payer name (a wire with a bare reference, a check from a third-party administrator you have never heard of, a patient payment through a bank bill-pay service). Book it to a suspense liability, not revenue, and run the payer's late or missing ERA procedure or the bank's ACH originator lookup. After the dormancy period, unidentified money is unclaimed property.

    SymptomUsual causeFix
    835 total exceeds deposit by a round percentage (2% to 5%)Virtual card or vendor fee deducted at settlementBook the fee as expense; opt out of VCC; demand the no-fee EFT
    Deposit exceeds any single 835Payer combined several 835s in one EFT, or combined lines of businessMatch the TRN to all 835s with that trace; sum them
    835 arrived, no deposit after 3 business daysBank account change not processed; payment sent to an old account or by checkLate/missing procedure with the payer; confirm EFT enrollment
    Deposit arrived, no 835 after 3 business daysERA enrollment lapsed, or the 835 went to a different clearinghouse or NPIRequest the 835 by TRN; check enrollment under every NPI
    Posted exceeds BPR02Recoupment (PLB WO) not posted; claim posted twicePost the PLB items; search duplicate payments by CLP07
    Posted is less than BPR02Claims in the exception queue; interest not postedClear exceptions before closing the batch
    Bank total agrees, but GL cash does notCut-off: posted in one month, deposited in the nextIn-transit schedule with dates; reverse next month

    Month-end close checklist

    Cash versus revenue

    Posting answers "what did we receive?" The month-end close also answers "what did we earn?" Net patient revenue is charges less contractual allowances less estimated bad debt and financial assistance, and the contractual allowance estimate is validated by the actual contractual adjustments posting records. A posting process that mislabels denials as contractual quietly inflates revenue until the auditors find it.

    Chapter 08

    Credit balances

    A credit balance is an account where payments and adjustments exceed charges. It is a liability, not a windfall: the money belongs to a payer, to a patient, or (after a dormancy period) to a state. Credit balances also distort A/R, because a −$300 account hides $300 of real receivables somewhere else in the same total.

    Where credits come from

    Duplicate payments

    The same claim paid twice, often because a corrected claim was adjudicated as a new one, or two payers both paid as primary.

    COB errors

    Primary and secondary both paid as if primary; or the secondary paid the full allowed instead of the primary's patient responsibility.

    Patient paid, then insurance paid

    Copay or deposit collected at the visit; the claim then adjudicated with no patient responsibility, or a lower one.

    Posting errors

    Payment posted to the wrong encounter, a contractual adjustment posted twice, a reversal posted without the reversal of its adjustments.

    Overpayment by the payer

    Paid above the contracted rate, paid for units not billed, paid a non-covered service, or paid after the patient's coverage ended.

    Charge corrections

    Charges reduced or removed after payment (a late credit from the department, a coding correction) leave the payment larger than the balance.

    Finding and working them

    1. 1

      Detect at posting Day 0

      Flag any payment that takes an encounter below zero, any payment above the expected allowed amount, and any secondary payment larger than the primary's patient responsibility. The best credit balance program prevents most credits at the posting edit.

    2. 2

      Run the credit report Weekly

      All accounts with a negative balance, aged from the date the credit arose, grouped by payer type. Separate true credits from false ones (unposted charges, a payment awaiting a charge, a pending reversal).

    3. 3

      Research Within 30 days of detection

      Reconstruct the account: charges, allowed, each payment with its source, each adjustment with its code. Determine the correct amount each party should have paid. The difference is the credit, and it tells you who it belongs to.

    4. 4

      Classify Same day as research

      Posting error (fix the posting, no money moves); payer overpayment (refund or allow recoupment, with a deadline for Medicare); patient overpayment (refund promptly); contractual true-up (a payer paid above contract: still a refund); unknown (escalate).

    5. 5

      Resolve and document Before the credit is 60 days old

      Issue the refund, post it against the credit, record the check or ACH number and the recipient. For a Medicare overpayment, report and return within the statutory deadline and keep the file.

    Credit balance classifierEnter what each party paid against one encounter. The tool computes the correct share for each, finds the credit, says who it belongs to, and sets the deadline that applies.

    Who gets the money

    Credit belongs toHow it is returnedDeadlineNotes
    Medicare (Parts A and B)Voluntary refund to the MAC with the overpayment form and claim detail, or a claim adjustment that triggers recoupment; self-disclosure protocols (OIG SDP, CMS SRDP) for issues involving potential fraud or StarkReport and return within 60 days of identification (suspended up to 180 days during a good-faith investigation); six-year lookbackHospitals file the CMS-838 credit balance report when Medicare credit balances exist (quarterly filing no longer required since December 1, 2024)
    Medicare Advantage planPer the plan's provider manual: refund check or request recoupment on a future remitPlan contract; the 60-day statute covers Medicare funds, so treat it as the outer limitMA organizations have their own 60-day duty to CMS and will recoup aggressively
    Medicaid or MCORefund to the state agency or the MCO per its procedureThe 60-day statute also applies to Medicaid overpayments; state rules may be shorterMedicaid patients generally cannot be billed cost sharing beyond state limits, so patient-side credits are rare but payer-side credits are common
    Commercial, fully insuredRefund check or authorized recoupment; many payers prefer offsetContract terms; many organizations set 30 to 60 days as policyState recoupment laws limit the payer's lookback (often 12 to 24 months) but do not limit your duty to refund
    Self-funded ERISA planRefund to the TPA or plan per the administrative agreementContract termsPlan assets; retaining them invites fiduciary claims from the plan
    Patient or guarantorRefund by check or card reversal to the person who paid; offset against another open balance only with consent or clear policyPromptly; policy of 30 days is common, some states mandate a periodUncashed refund checks become unclaimed property after the dormancy period
    UnknownResearch; if still unknown after the state's dormancy period, report and remit as unclaimed propertyState unclaimed property deadlineNever move an unknown credit to income
    Netting is not resolving

    A credit on one encounter and a debit on another for the same patient do not cancel each other unless the policy says so and the patient has been told. Applying a payer's overpayment to the patient's unpaid balance is never allowed: the payer's money is the payer's. Offsetting one payer's credit against the same payer's underpayment elsewhere needs the payer's agreement, usually through its recoupment process.

    Small-balance write-offs in reverse

    Writing off a $4 credit the way you write off a $4 debit feels symmetrical. It is not: the $4 is someone else's money, and most state unclaimed property laws have no minimum. Set a policy for aggregating small credits into a single refund or escheat report, and apply it consistently. Reversing old credits into income is the audit finding that converts an accounting error into a legal problem.

    Chapter 09

    Refunds, the Medicare 60-day rule, and unclaimed property

    Returning money is a regulated act. For Medicare and Medicaid, federal law sets the clock and the penalty. For patients and commercial payers, contracts and state law set the terms. For money nobody claims, every state has an unclaimed property statute with its own dormancy period and reporting cycle.

    The Medicare 60-day overpayment rule

    Section 1128J(d) of the Social Security Act (42 USC 1320a-7k(d)), added by the Affordable Care Act, requires anyone who has received an overpayment from Medicare or Medicaid to report and return it within 60 days of the date it was identified (or the date a corresponding cost report is due, if later). An overpayment retained past the deadline is an "obligation" under the False Claims Act, which is what gives the rule its teeth: treble damages plus per-claim penalties, currently $14,308 to $28,619 after the 2025 inflation adjustment. CMS's implementing rule for Parts A and B is at 42 CFR 401.301 to 401.305; the lookback period is six years from the date the overpayment was received.

    The CY 2025 Physician Fee Schedule final rule, effective January 1, 2025, changed two things that matter to every posting and credit balance team:

    "Identified" now means "knowingly"

    Actual knowledge, reckless disregard, or deliberate ignorance

    The 2016 rule said an overpayment was identified when a provider "has, or should have through the exercise of reasonable diligence," determined that it received an overpayment and quantified it. The 2025 rule replaced that with the False Claims Act's knowledge standard: a person has identified an overpayment when the person knowingly receives or retains it, where knowingly means actual knowledge, reckless disregard or deliberate ignorance (31 USC 3729(b)(1)(A)). Quantification is no longer part of the definition, so the clock can start before the amount is known.

    A formal 180-day investigation window

    Suspension of the 60 days, not an extension

    When a provider has identified an overpayment and is conducting a timely, good-faith investigation to find related overpayments from the same or similar cause, the 60-day deadline is suspended until the earlier of the end of the investigation (with the total calculated) or 180 days after the initial identification. The 60 days then run. In practice that is a maximum of about 240 days from identification to return, and only if the investigation is real, documented and timely. The same standard applies to Part C and Part D organizations (42 CFR 422.326 and 423.360), which do not get the 180-day suspension.

    What "report and return" looks like

    RouteWhen to use itMechanics
    Claim adjustmentA single claim or a small set paid wrong for an identifiable reason (wrong units, wrong code, duplicate)Submit a corrected or voided claim; the MAC reprocesses and recoups the difference on a future remittance (PLB WO or claim reversal). Keep the 835 as proof of return
    Voluntary refundOverpayments you have quantified and do not want to wait on recoupment for; patterns across claimsMAC overpayment refund form, check or ACH, claim listing with reasons. The MAC acknowledges with a PLB 72 (authorized return) paired with a WO on a later 835
    Requested offsetYou prefer the MAC to take it from future paymentsWritten request for immediate recoupment; treated as a voluntary repayment and not charged interest
    Extended repayment scheduleThe amount cannot be repaid at once without hardshipRequest with financial documentation; MACs approve shorter schedules, longer ones need CMS approval; interest accrues
    OIG Self-Disclosure ProtocolConduct that may violate federal criminal, civil or administrative law (false billing, kickbacks)Submission to OIG with the calculation and corrective action; resolution usually at a multiple of single damages but without exclusion
    CMS Self-Referral Disclosure ProtocolActual or potential Stark law violations onlySubmission to CMS; the 60-day clock is suspended while the SRDP is pending
    Medicare credit balance report (CMS-838)Hospitals and other Part A providers with Medicare credit balances on their booksSince December 1, 2024 the report is filed when credit balances occur rather than every quarter; self-identified overpayments must still be reported and returned
    What the 60-day rule changes in daily work
    • The credit balance report is a compliance document. A Medicare credit on the books that nobody has researched is, after the new standard, a candidate for "reckless disregard." Age it from the date it arose and work it on a schedule.
    • Write the investigation down. If one duplicate payment suggests a pattern, open an investigation file with the date identified, the scope, the sampling approach and the end date. The 180-day suspension only exists for an investigation that is "timely" and in "good faith."
    • Do not wait for the payer. A payer's failure to recoup does not relieve you. Your obligation runs from your knowledge.
    • Separate the compliance call from the cash call. Posting staff identify; compliance decides the route (adjustment, refund, SDP, SRDP). Both decisions are logged.

    Refunding patients

    Confirm the payer side first
    A patient credit that exists because the secondary payer paid the deductible is a patient refund only if the secondary was right to pay it. Finish the COB picture before writing the check.
    Refund to the person who paid, by the method they used
    Card payments are reversed to the card where the processor allows; checks and cash are refunded by check or ACH to the guarantor. Refunds to a different person need written authorization.
    Set a service standard
    A written policy such as "patient refunds issued within 30 days of identification" is common and defensible. Some states impose deadlines for refunding patient overpayments; check yours.
    Offsets need consent
    Applying a credit on one encounter to an older balance on another is acceptable for the same guarantor when the statement explains it, but a credit should never be held against a balance that is in dispute or still with the payer.
    Track the check
    An uncashed refund check is still the patient's money. Stale checks go on the due-diligence list, not back into income.
    QMB and Medicaid patients
    Medicare cost sharing collected from a Qualified Medicare Beneficiary must be refunded; the provider may not bill it. Medicaid cost sharing above state limits likewise.

    Unclaimed property (escheat)

    Every state has an unclaimed property law. A credit balance or an uncashed refund check that the owner has not claimed after the dormancy period (commonly three to five years, set by state and property type; one year for payroll) must be reported and remitted to the state of the owner's last known address, or to the holder's state of incorporation if the address is unknown. Before remitting, most states require a due-diligence notice to the owner above a small dollar threshold, sent a set number of months before the report. Reports are annual, with filing deadlines that differ by state (many in the fall, some in the spring).

    Three things catch providers: states have no statute of limitations for unfiled reports and may audit back many years, using estimation when records are gone; many states have no minimum amount, so a $20 credit is reportable; and reversing dormant credits into income ("cleaning up" the aged credit report) is unlawful in every state. Voluntary disclosure agreements usually waive penalties and interest for a holder that comes forward before an audit.

    Dormancy

    Commonly 3 to 5 years

    Measured from the date the credit arose or the check was issued, not from the last statement you sent. Keep that date on the account.

    Due diligence

    Letter before remittance

    Written notice to the last known address for amounts above the state's threshold, within the state's window before the report. Document the mailing.

    Audit exposure

    No limitations period

    Multi-state audits (often contingency-fee auditors) can go back a decade or more. The cure is an annual report, filed, with a reconciliation to the credit balance ledger.

    Chapter 10

    Controls and KPIs

    Posting is a control environment before it is a workflow. The metrics below tell a manager whether cash is complete, timely and honest; the controls tell an auditor that it stays that way when nobody is watching.

    The measures

    MetricFormulaCommon targetWhat a bad number means
    ERA and EFT rateRemittance dollars (or counts) received as 835 ÷ total; payments by EFT ÷ totalAbove the national 89% / 78%; pursue every payer that offers themManual posting cost, float, keying errors, VCC fees
    Auto-post rate835 claims posted without manual touch ÷ 835 claims receivedCommonly 85% to 95% for professional billingRules too tight, control numbers not matching, contracts not loaded
    Posting lagDays from EFT effective date (or deposit) to posting dateWithin 1 to 2 business days; same day for 835sStatements sent on stale balances; follow-up working paid claims
    Unapplied cashUnapplied dollars ÷ monthly cash receipts; count over 30 daysWell under 1% of monthly cash; nothing over 30 daysRevenue recognized late; wrong statements; reconciliation plugs
    Unidentified depositsDollars in suspense with no remittanceZero at month-end older than 30 daysMissing 835s; enrollment problems; future escheat
    Reconciliation variancePosted − deposited, by day and monthZero, with every in-transit item datedUnposted recoupments, duplicate postings, fees not booked
    Credit balance dollars and agingSum of negative balances; share older than 60 and 90 days; by payer typeFalling trend; nothing Medicare-related older than 60 days unresolvedCompliance exposure, overstated collections, escheat liability
    Refund turnaroundDays from credit identification to refund issuedUnder 30 days for patients; within the 60-day rule for MedicarePatient complaints, FCA exposure
    Denials captured at postingZero-pay and denied lines routed to the denial queue ÷ denied lines on 835s100%; no CO denial auto-written-offRevenue leakage disguised as contractual allowance
    Contractual varianceActual contractual adjustments − expected under loaded contractsExplained monthly; underpayments appealedContracts loaded wrong, or payer paying wrong
    Takeback ratePLB WO and reversal dollars ÷ cash receipts, by payerLow and stable; spikes investigatedAudit activity, COB failures, eligibility problems upstream

    Controls that auditors look for

    Segregation of duties

    Three hands

    Receiving and depositing cash, posting it, and reconciling it are separate roles, and none of them can issue a refund or approve a write-off above a low threshold alone. In a small office, the physician-owner reviews the bank statement and the refund list.

    Control totals and batch logs

    Nothing posts without a header

    Every batch carries source, date, count and amount, and closes only when posted equals the header. The log is the reconciliation's starting point.

    Write-off and refund approval matrix

    Thresholds by role

    Posting staff may post contractual adjustments and PR transfers; denial write-offs, small-balance write-offs above a limit and all refunds need a second approver, with the reason captured in the transaction.

    Edit rules under change control

    Auto-post rules are code

    A rule change that converts a denial CARC into a contractual adjustment changes net revenue. Rules have owners, version history and a quarterly review against the CARC list and CORE 360 combinations.

    Credit balance governance

    Weekly report, named owners, compliance visibility

    The aged credit report goes to a standing review with billing, finance and compliance. Medicare and Medicaid credits are tracked from identification date against the 60-day deadline.

    Exception queue hygiene

    Nothing lives in the queue

    Unapplied, unmatched, out-of-balance and unreferenced PLB items each have an owner and a maximum age. The queue count is reported daily.

    A one-page daily cash dashboard

    Yesterday's deposits by channel; 835s received and posted (count, dollars, auto-post rate); exceptions opened and closed; unapplied balance and oldest item; unidentified deposits; recoupments posted; refunds issued; credit balance total and the oldest Medicare credit. If a manager can read it in two minutes, the process is under control. If any line is blank, it is not.

    Chapter 11

    Rules and regulations

    The rules below govern how payments must be sent and explained, when money must be returned, and what happens when it is not. Contracts and state law fill the gaps for commercial payers and patients.

    Federal · HIPAA administrative simplification

    45 CFR Part 162: standard transactions and operating rules

    Health plans must conduct the health care claim payment and remittance advice transaction using the ASC X12N 835 (version 005010X221A1) and the electronic funds transfer using the NACHA CCD+ with the X12 835 TRN segment in the addenda record (45 CFR 162.1601 and 162.1602). Health plans must comply with the CAQH CORE Phase III EFT and ERA operating rules (45 CFR 162.1603), effective January 1, 2014, including reassociation (CORE 370), uniform CARC and RARC combinations (CORE 360) and standard enrollment data (CORE 380 and 382). CMS's HIPAA FAQs add that a plan cannot require virtual credit card payment, must honor a request for standard EFT, and may not impose fees on the standard EFT beyond the provider's own bank charge. Complaints go to the CMS administrative simplification enforcement process.

    Federal · Overpayments

    Social Security Act 1128J(d); 42 CFR 401.301–401.305; 42 CFR 422.326 and 423.360

    Report and return Medicare and Medicaid overpayments within 60 days of identification. Since January 1, 2025 "identified" uses the False Claims Act knowledge standard (actual knowledge, reckless disregard or deliberate ignorance), and the 60-day period is suspended for up to 180 days while a timely, good-faith investigation of related overpayments is under way (Parts A and B). The lookback is six years. Retained overpayments are FCA obligations (31 USC 3729) and can draw civil monetary penalties under 42 CFR 1003.210. Medicare Advantage and Part D organizations have parallel duties.

    Federal · Medicare collections

    42 CFR 405.370–405.379; 42 CFR 401.607; 42 CFR 424.510(e)

    Medicare contractors demand overpayments of $25 or more; interest accrues from day 31 at the rate published quarterly (11.875% from July 21, 2026); recoupment begins at day 41; a rebuttal is due within 15 days and a redetermination within 120 days; filing the redetermination by day 30 (and reconsideration by day 60 after an unfavorable redetermination) suspends recoupment under section 935 of the MMA. Extended repayment schedules are available on a showing of hardship. Providers must accept EFT as a condition of Medicare enrollment.

    Federal · Medicare credit balance reporting

    CMS Pub. 100-06, chapter 12; Form CMS-838

    Providers paid under Part A report Medicare credit balances on the CMS-838. Effective December 1, 2024, CMS removed the requirement to file the report every calendar quarter; a report is filed when Medicare credit balances occur, and self-identified overpayments must still be reported and returned under the 60-day rule. Contractors may still require a signed certification; follow your MAC's instructions.

    Federal · False Claims Act

    31 USC 3729–3733

    Knowingly retaining an identified overpayment past the deadline is a "reverse false claim." Liability is three times the government's damages plus a per-claim penalty of $14,308 to $28,619 (2025 inflation adjustment, applied to penalties assessed after July 3, 2025; adjusted annually). Qui tam relators, including former billing staff, may bring the case.

    State · Payer recoupment limits and prompt pay

    State insurance codes

    Many states limit how long a fully insured plan has to recoup an overpayment, commonly 12 to 24 months from payment, with notice, an explanation and a dispute period required first (Ohio reduced its window from 24 to 12 months in 2025). Fraud and coordination-of-benefits cases are usually excepted, and self-funded ERISA plans generally assert preemption. State prompt-pay laws require interest on clean claims paid late, which arrives as AMT*I and PLB L6 on the 835.

    State · Unclaimed property

    State unclaimed property acts (many based on the Uniform Unclaimed Property Act or its 2016 revision)

    Patient credit balances, uncashed refund checks and unidentified payments become reportable after the dormancy period (commonly three to five years) and must be remitted to the state of the owner's last known address after due-diligence notice. Annual reports, penalties and interest for late filing, no statute of limitations for unfiled reports, and voluntary disclosure programs are standard features. Medicare and Medicaid overpayments are not unclaimed property; they are returned to the program.

    Federal · Patient protections

    QMB billing prohibition; No Surprises Act; FDCPA

    Providers may not collect Medicare cost sharing from Qualified Medicare Beneficiaries and must refund any collected (SSA 1902(n)(3)(B)). Refunds of amounts collected above the No Surprises Act's in-network cost-sharing limits for protected out-of-network services are required (with interest in some cases, 45 CFR 149.410 to 149.420). Patient refund and billing conduct also falls under state consumer protection and, for agencies, the FDCPA.

    Chapter 12

    Key numbers 2026–27

    ItemFigureContext
    Standards and operating rules
    ERA standardX12 835, 005010X221A145 CFR 162.1602
    EFT standardNACHA CCD+ with 835 TRN addenda45 CFR 162.1602; TRN in addenda field 3
    Operating rules effectiveJan 1, 2014CAQH CORE Phase III, 45 CFR 162.1603
    835 release window around the EFT effective date±3 business daysCORE 370; 90% of transactions per month must comply
    EFT or ERA considered late or missingafter 4 business daysCMS reassociation guidance; use the plan's resolution procedure
    EFT enrollment / ERA enrollment data elements~70 / ~65CORE 380 and 382 maximum data sets
    Adoption and cost (CAQH Index)
    Medical claim payments by EFT, 202478%2025 CAQH Index (up from 73% in the 2023 Index); dental 33%
    Medical remittances fully electronic (835)89%2024 CAQH Index (CAQH Index is now the DataSpring Index); 6% partially electronic, 5% manual
    Provider cost per remittance, manual vs electronic$5.67 vs $2.952024 CAQH Index; $2.72 saved per transaction
    Provider cost per claim payment, manual vs electronic$4.99 vs $3.162024 CAQH Index; industry opportunity $449 million
    Remittance advice savings opportunity$695 million2024 CAQH Index, mostly provider side
    Fees and interest
    Virtual credit card fees reported to CMSup to 5%AMA and MGMA; EFT vendor fees of 1.5% to 2% also reported
    Legitimate cost of a standard EFT to the providerbank fee only (~$0.34 avg.)CMS HIPAA FAQ
    Medicare overpayment interest rate11.875%From July 21, 2026; 11.375% the prior quarter; reset quarterly
    Medicare sequestration (CO-253)2%In effect; 4% PAYGO sequester for 2026 waived Nov 2025
    Overpayment deadlines
    Report and return Medicare/Medicaid overpayments60 daysFrom identification; SSA 1128J(d)
    Investigation suspension (Parts A and B)up to 180 days42 CFR 401.305(b)(3), since Jan 1, 2025; about 240 days maximum in total
    Lookback6 yearsFrom receipt of the overpayment
    Medicare demand letter: rebuttal / interest / recoupment / redetermination15 / 31 / 41 / 120 daysRedetermination by day 30 stops recoupment (section 935)
    Minimum demanded overpayment$25MLN overpayment guidance
    FCA per-claim penalty$14,308–$28,6192025 adjustment; plus treble damages
    CMS-838 quarterly filingended Dec 1, 2024File when Medicare credit balances occur
    State rules (typical)
    Payer recoupment lookback12–24 monthsFully insured plans; Ohio 12 months since 2025
    Unclaimed property dormancy3–5 yearsCredit balances and uncashed checks; 1 year payroll

    What is changing

    In effect since 2025

    Knowledge-based "identified" and the 180-day window

    The 60-day rule now turns on what you knew or recklessly ignored, and rewards a documented investigation. Credit balance aging is a compliance report.

    In effect since Dec 2024

    CMS-838 on occurrence, not quarterly

    Fewer blank certifications, but the duty to report Medicare credits when they exist is unchanged. Keep the internal quarterly review anyway.

    Watch in 2026–27

    Payment vendors and state recoupment laws

    More payers route payments through vendors that default to VCC or fee-bearing EFT; more states are shortening recoupment lookbacks. Re-read enrollment terms annually and track your states' laws.

    Sources

    1. CMS: EFT and ERA payment and remittance reassociation basics (CORE 370 timing, TRN, late or missing)
    2. CAQH CORE: Phase III EFT and ERA operating rules overview (rules 350, 360, 370, 380, 382)
    3. CMS: Operating rules for EFT and remittance advice (effective January 1, 2014; EFT standard)
    4. AMA: CMS guidance on virtual credit card and EFT fees
    5. Foley & Lardner: CMS final regulations on the 60-day refund rule (identified standard, 180-day suspension, effective January 1, 2025)
    6. Reed Smith: CY 2025 PFS rule and the Medicare overpayment standard
    7. CMS MLN: Medicare overpayments (demand letter, interest, recoupment, six-year lookback)
    8. Noridian: Medicare overpayment interest rates by quarter
    9. Noridian: CMS-838 credit balance report (quarterly requirement ended December 1, 2024)
    10. BCBS Illinois: Interpreting the PLB segment on the 835 (sign convention, WO, L6, 72)
    11. CAQH Index 2024: claim payment and remittance advice adoption and cost
    12. AJMC: 2025 CAQH Index findings (78% medical claim payment adoption)
    13. Sidley: 2025 inflation adjustment to False Claims Act penalties
    14. Advisory Board: Medicare sequestration status (2% in effect; PAYGO sequester waived)
    15. ADA News (September 2026): payer recoupments and state lookback limits
    16. Baker Tilly: unclaimed property and patient credit balances
    Chapter 13

    Glossary

    Chapter 14

    Knowledge check

    Eight questions drawn from the chapters above. Pick an answer to see the explanation.

    Score: 0 / 8

    For training and reference. This page summarizes general rules and does not replace payer contracts, plan documents, CMS manuals, state law or legal advice. Example names, IDs, claim numbers, trace numbers, bank details and payers are fictional.

    Figures checked October 15, 2026.