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.
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.
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.
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.
Remit totals, deposits and posted amounts must reconcile daily and close monthly.
Credit balances are liabilities with deadlines: refund, offset, report or escheat.
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.
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.
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 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.
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.
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.
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.
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.
Overpayments nobody researches. They understate A/R, they are owed to someone, and for Medicare they become reportable overpayments with a 60-day clock.
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.
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.
| Channel | The money | The explanation | Matching key | Watch for |
|---|---|---|---|---|
| EFT + ERA (the HIPAA standard pair) | ACH CCD+ credit to the provider's bank account | X12 835 delivered by the payer or through a clearinghouse | TRN trace number in the CCD+ addenda and in the 835 TRN segment | Timing gap between EFT and 835; multiple 835s under one EFT; payer-side enrollment errors sending money to an old account |
| Paper check + paper EOB | Check mailed to the office or to a bank lockbox | Paper explanation of benefits, often also available as a PDF on the payer portal | Check number and payer claim number | Manual keying errors; lockbox images that cut off the EOB; checks held in a drawer and deposited late |
| Check + 835 | Paper check (BPR04 = CHK) | 835 with the check number in TRN02 | TRN02 = check number | Posting 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 terminal | Separate remittance, often a PDF, sometimes an 835 with BPR04 = NON | Card payment reference | Merchant fees of up to 5% deducted from the payment; the deposit never equals the remittance; the provider can refuse VCC and demand EFT |
| Patient payments | Card, cash, check, portal, payment plan, HSA card | Receipt, statement reference, portal transaction ID | Guarantor account and encounter | Copays posted to the wrong encounter; plan installments posted as lump sums; cash control at the front desk |
| Capitation and other non-claim payments | Monthly ACH or check | Membership roster; PLB entries on an 835 (CT capitation payment, IP incentive premium) | Contract and month | Must not be posted to patient accounts; belongs in GL revenue for the contract |
| Settlements, interest, recoupments | Netted inside an EFT | PLB segment on the 835 (L6 interest, WO recoupment, LS lump sum) | PLB03-2 reference, usually the payer claim number | These change the check total without being claim payments; they need their own posting rules |
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.
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.
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.
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.
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.
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.
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.
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.
| Layer | Segments | What it carries | Posting use |
|---|---|---|---|
| Header | ST, BPR, TRN, CUR, REF, DTM | Payment 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 payee | N1*PR, N3, N4, REF*2U, PER; N1*PE, REF*TJ | Who 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, QTY | One CLP per claim: status, billed, paid, patient responsibility, payer claim number; claim-level adjustments; patient, insured, rendering provider; Medicare inpatient (MIA) and outpatient (MOA) details | Find the account by CLP01 (your patient control number); post claim-level amounts |
| Service loop (2110) | SVC, DTP, CAS, REF, AMT, QTY, LQ | One 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 |
| Trailer | PLB, SE | Provider-level adjustments that change the check without touching a claim; segment count | Post recoupments to the referenced claims, interest to non-patient revenue; balance the batch |
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.
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.
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.
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.
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.
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.
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*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.
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.
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.
| Level | Rule | Example from the sample |
|---|---|---|
| Service line | SVC02 charge = SVC03 paid + Σ line CAS amounts | $1,800 = $440 + $850 (CO-45) + $400 (PR-1) + $110 (PR-2) |
| Claim | CLP03 charge = CLP04 paid + Σ claim CAS + Σ line CAS; CLP05 = Σ PR amounts | $2,150 = $590 + $1,020 (CO) + $540 (PR) |
| Transaction | BPR02 = Σ CLP04 − Σ PLB04 | $468.42 = ($590 + $0) − ($125.00 − $3.42) |
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.
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.
| Rule | Name | What it requires | What it means for posting |
|---|---|---|---|
| CORE 350 | 835 infrastructure | Connectivity, batch acknowledgments, and companion guide format for the 835 | Your clearinghouse should acknowledge every file; a missing 835 is detectable |
| CORE 360 | Uniform use of CARCs and RARCs | Payers 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 payers | Auto-posting rules can key on code combinations rather than payer-specific habits |
| CORE 370 | EFT and ERA reassociation | The 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 procedures | If 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 380 | EFT enrollment data | A maximum standard set of about 70 data elements for EFT enrollment, offered electronically, with a defined template | Enrollment paperwork should look the same across payers; refuse non-standard demands |
| CORE 382 | ERA enrollment data | About 65 standard elements for ERA enrollment, also offered electronically | Enroll for ERA and EFT together, and update both when a bank account or clearinghouse changes |
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.
The 835 carries the identical TRN02 and TRN03, BPR16 equal to the effective entry date, and BPR02 equal to the ACH amount.
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.
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.
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.
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.
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.
| 835 element | Auto-post action | Exception trigger |
|---|---|---|
| CLP01 → account | Find the encounter by your patient control number; confirm the patient name and date of service | No match, or more than one match: route to unapplied queue with the payer claim number |
| CLP04 paid | Post as insurance payment from the payer in N1*PR, dated the EFT effective date | Payment 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 line | Adjustment larger than expected under the loaded contract: underpayment review |
| CAS*PR*1, 2, 3 | Transfer deductible, coinsurance, copay to patient responsibility, or to the secondary payer if one is on file | PR 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 queue | Never auto-write-off. A rule that writes off every CO code is the most expensive rule in the system |
| CAS*OA*23 | Record the prior payer's payment impact on a secondary remit; no write-off | Secondary paid more than the primary's patient responsibility: credit balance check |
| CAS*CO*253 | Post sequestration as a contractual adjustment | None; 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 CARC | Always 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 file | No 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 separately | No secondary remittance within the expected window |
| AMT*I, PLB L6 | Post interest to a non-patient interest income account | Interest posted to a patient account creates a false credit |
| PLB WO, FB, 72, CS | Post to the referenced claim per chapter 06 rules | No reference: hold in a provider-level suspense account until identified |
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.
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.
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.
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.
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 shows | What it means | Posting |
|---|---|---|
| CLP02 = 4, CAS*CO*197 | Denied, no authorization | Denial adjustment code, balance open, denial queue; patient not billable in network |
| CLP02 = 1, CLP04 = 0, CAS*PR*1 for the full allowed | Processed, applied to deductible | Contractual for charge minus allowed; transfer the allowed to the patient (or secondary) |
| CLP02 = 1, CLP04 > 0, PLB WO equal to the sum | Paid, but the whole check was taken for a prior overpayment | Post the claim payments normally and the recoupment to the referenced claims; the net deposit is zero |
| CLP02 = 22 with negative amounts, no replacement | Reversal only; the payer withdrew the earlier adjudication | Reverse 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 amount | Not covered; patient responsibility per plan terms | Transfer to patient only if the plan says PR; CO means the provider absorbs it |
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.
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.
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.
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.
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.
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.
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.
| Code | Name | Usual sign | What happened | Posting |
|---|---|---|---|---|
WO | Overpayment recovery | Positive (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 check | Post 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 |
FB | Forwarding balance | Negative now, positive later | A 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 it | Negative FB: record a payer receivable for the deferred takeback; positive FB: clear it. Never post FB to a patient account |
L6 | Interest owed | Negative (increases the check) | Interest the payer owes for late payment (prompt-pay interest), often the sum of claim-level AMT*I amounts | Interest income, non-patient. Not revenue on any claim |
72 | Authorized return | Negative, paired with a positive WO | The payer acknowledges a refund check you sent or a voided check; the pair nets to zero | No posting if the refund was already posted when issued; otherwise post the refund and the recovery together |
CS | Adjustment | Either | Catch-all: a reissued payment for a lost check, a correction to a prior PLB, a write-down of an FB balance, Medicare pass-through items | Read the reference and the payer's description; hold in provider-level suspense until identified |
50 | Late charge | Positive | Medicare: penalty for a late cost report | Expense, not a patient account |
51 | Interest penalty charge | Positive | Interest charged to the provider on an overpayment debt | Interest expense |
IR | Internal Revenue Service withholding | Positive | Backup withholding sent to the IRS, usually a missing or mismatched W-9 | Tax receivable; fix the W-9 with the payer immediately |
LS | Lump sum | Negative | Bonus or settlement payments: quality program payments, Medicare pass-throughs such as indirect medical education | Contract or program revenue in the GL |
PI | Periodic interim payment | Negative | Medicare PIP payments to hospitals on a schedule rather than per claim | GL, reconciled at cost report settlement |
BD | Bad debt adjustment | Negative | Medicare bad debt reimbursement | GL |
CT / IP | Capitation payment / incentive premium | Negative | Monthly capitation or incentive payments carried on an 835 | Contract revenue; never a patient account |
AH | Origination fee | Positive | A fee deducted from the payment | Expense; challenge it if it is an EFT fee the payer may not charge |
WU | Unspecified recovery | Positive | A recoupment the payer did not tie to a claim | Suspense; demand the claim detail |
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.
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).
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.
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.
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.
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."
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.
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 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.
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.
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.
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.
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.
| Symptom | Usual cause | Fix |
|---|---|---|
| 835 total exceeds deposit by a round percentage (2% to 5%) | Virtual card or vendor fee deducted at settlement | Book the fee as expense; opt out of VCC; demand the no-fee EFT |
| Deposit exceeds any single 835 | Payer combined several 835s in one EFT, or combined lines of business | Match the TRN to all 835s with that trace; sum them |
| 835 arrived, no deposit after 3 business days | Bank account change not processed; payment sent to an old account or by check | Late/missing procedure with the payer; confirm EFT enrollment |
| Deposit arrived, no 835 after 3 business days | ERA enrollment lapsed, or the 835 went to a different clearinghouse or NPI | Request the 835 by TRN; check enrollment under every NPI |
| Posted exceeds BPR02 | Recoupment (PLB WO) not posted; claim posted twice | Post the PLB items; search duplicate payments by CLP07 |
| Posted is less than BPR02 | Claims in the exception queue; interest not posted | Clear exceptions before closing the batch |
| Bank total agrees, but GL cash does not | Cut-off: posted in one month, deposited in the next | In-transit schedule with dates; reverse next month |
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.
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.
The same claim paid twice, often because a corrected claim was adjudicated as a new one, or two payers both paid as primary.
Primary and secondary both paid as if primary; or the secondary paid the full allowed instead of the primary's patient responsibility.
Copay or deposit collected at the visit; the claim then adjudicated with no patient responsibility, or a lower one.
Payment posted to the wrong encounter, a contractual adjustment posted twice, a reversal posted without the reversal of its adjustments.
Paid above the contracted rate, paid for units not billed, paid a non-covered service, or paid after the patient's coverage ended.
Charges reduced or removed after payment (a late credit from the department, a coding correction) leave the payment larger than the balance.
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.
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).
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.
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).
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 belongs to | How it is returned | Deadline | Notes |
|---|---|---|---|
| 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 Stark | Report and return within 60 days of identification (suspended up to 180 days during a good-faith investigation); six-year lookback | Hospitals file the CMS-838 credit balance report when Medicare credit balances exist (quarterly filing no longer required since December 1, 2024) |
| Medicare Advantage plan | Per the plan's provider manual: refund check or request recoupment on a future remit | Plan contract; the 60-day statute covers Medicare funds, so treat it as the outer limit | MA organizations have their own 60-day duty to CMS and will recoup aggressively |
| Medicaid or MCO | Refund to the state agency or the MCO per its procedure | The 60-day statute also applies to Medicaid overpayments; state rules may be shorter | Medicaid patients generally cannot be billed cost sharing beyond state limits, so patient-side credits are rare but payer-side credits are common |
| Commercial, fully insured | Refund check or authorized recoupment; many payers prefer offset | Contract terms; many organizations set 30 to 60 days as policy | State recoupment laws limit the payer's lookback (often 12 to 24 months) but do not limit your duty to refund |
| Self-funded ERISA plan | Refund to the TPA or plan per the administrative agreement | Contract terms | Plan assets; retaining them invites fiduciary claims from the plan |
| Patient or guarantor | Refund by check or card reversal to the person who paid; offset against another open balance only with consent or clear policy | Promptly; policy of 30 days is common, some states mandate a period | Uncashed refund checks become unclaimed property after the dormancy period |
| Unknown | Research; if still unknown after the state's dormancy period, report and remit as unclaimed property | State unclaimed property deadline | Never move an unknown credit to income |
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.
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.
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.
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:
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.
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.
| Route | When to use it | Mechanics |
|---|---|---|
| Claim adjustment | A 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 refund | Overpayments you have quantified and do not want to wait on recoupment for; patterns across claims | MAC 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 offset | You prefer the MAC to take it from future payments | Written request for immediate recoupment; treated as a voluntary repayment and not charged interest |
| Extended repayment schedule | The amount cannot be repaid at once without hardship | Request with financial documentation; MACs approve shorter schedules, longer ones need CMS approval; interest accrues |
| OIG Self-Disclosure Protocol | Conduct 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 Protocol | Actual or potential Stark law violations only | Submission 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 books | Since December 1, 2024 the report is filed when credit balances occur rather than every quarter; self-identified overpayments must still be reported and returned |
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.
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.
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.
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.
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.
| Metric | Formula | Common target | What a bad number means |
|---|---|---|---|
| ERA and EFT rate | Remittance dollars (or counts) received as 835 ÷ total; payments by EFT ÷ total | Above the national 89% / 78%; pursue every payer that offers them | Manual posting cost, float, keying errors, VCC fees |
| Auto-post rate | 835 claims posted without manual touch ÷ 835 claims received | Commonly 85% to 95% for professional billing | Rules too tight, control numbers not matching, contracts not loaded |
| Posting lag | Days from EFT effective date (or deposit) to posting date | Within 1 to 2 business days; same day for 835s | Statements sent on stale balances; follow-up working paid claims |
| Unapplied cash | Unapplied dollars ÷ monthly cash receipts; count over 30 days | Well under 1% of monthly cash; nothing over 30 days | Revenue recognized late; wrong statements; reconciliation plugs |
| Unidentified deposits | Dollars in suspense with no remittance | Zero at month-end older than 30 days | Missing 835s; enrollment problems; future escheat |
| Reconciliation variance | Posted − deposited, by day and month | Zero, with every in-transit item dated | Unposted recoupments, duplicate postings, fees not booked |
| Credit balance dollars and aging | Sum of negative balances; share older than 60 and 90 days; by payer type | Falling trend; nothing Medicare-related older than 60 days unresolved | Compliance exposure, overstated collections, escheat liability |
| Refund turnaround | Days from credit identification to refund issued | Under 30 days for patients; within the 60-day rule for Medicare | Patient complaints, FCA exposure |
| Denials captured at posting | Zero-pay and denied lines routed to the denial queue ÷ denied lines on 835s | 100%; no CO denial auto-written-off | Revenue leakage disguised as contractual allowance |
| Contractual variance | Actual contractual adjustments − expected under loaded contracts | Explained monthly; underpayments appealed | Contracts loaded wrong, or payer paying wrong |
| Takeback rate | PLB WO and reversal dollars ÷ cash receipts, by payer | Low and stable; spikes investigated | Audit activity, COB failures, eligibility problems upstream |
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.
Every batch carries source, date, count and amount, and closes only when posted equals the header. The log is the reconciliation's starting point.
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.
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.
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.
Unapplied, unmatched, out-of-balance and unreferenced PLB items each have an owner and a maximum age. The queue count is reported daily.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
| Item | Figure | Context |
|---|---|---|
| Standards and operating rules | ||
| ERA standard | X12 835, 005010X221A1 | 45 CFR 162.1602 |
| EFT standard | NACHA CCD+ with 835 TRN addenda | 45 CFR 162.1602; TRN in addenda field 3 |
| Operating rules effective | Jan 1, 2014 | CAQH CORE Phase III, 45 CFR 162.1603 |
| 835 release window around the EFT effective date | ±3 business days | CORE 370; 90% of transactions per month must comply |
| EFT or ERA considered late or missing | after 4 business days | CMS reassociation guidance; use the plan's resolution procedure |
| EFT enrollment / ERA enrollment data elements | ~70 / ~65 | CORE 380 and 382 maximum data sets |
| Adoption and cost (CAQH Index) | ||
| Medical claim payments by EFT, 2024 | 78% | 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 $2.95 | 2024 CAQH Index; $2.72 saved per transaction |
| Provider cost per claim payment, manual vs electronic | $4.99 vs $3.16 | 2024 CAQH Index; industry opportunity $449 million |
| Remittance advice savings opportunity | $695 million | 2024 CAQH Index, mostly provider side |
| Fees and interest | ||
| Virtual credit card fees reported to CMS | up to 5% | AMA and MGMA; EFT vendor fees of 1.5% to 2% also reported |
| Legitimate cost of a standard EFT to the provider | bank fee only (~$0.34 avg.) | CMS HIPAA FAQ |
| Medicare overpayment interest rate | 11.875% | 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 overpayments | 60 days | From identification; SSA 1128J(d) |
| Investigation suspension (Parts A and B) | up to 180 days | 42 CFR 401.305(b)(3), since Jan 1, 2025; about 240 days maximum in total |
| Lookback | 6 years | From receipt of the overpayment |
| Medicare demand letter: rebuttal / interest / recoupment / redetermination | 15 / 31 / 41 / 120 days | Redetermination by day 30 stops recoupment (section 935) |
| Minimum demanded overpayment | $25 | MLN overpayment guidance |
| FCA per-claim penalty | $14,308–$28,619 | 2025 adjustment; plus treble damages |
| CMS-838 quarterly filing | ended Dec 1, 2024 | File when Medicare credit balances occur |
| State rules (typical) | ||
| Payer recoupment lookback | 12–24 months | Fully insured plans; Ohio 12 months since 2025 |
| Unclaimed property dormancy | 3–5 years | Credit balances and uncashed checks; 1 year payroll |
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.
Fewer blank certifications, but the duty to report Medicare credits when they exist is unchanged. Keep the internal quarterly review anyway.
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.
Eight questions drawn from the chapters above. Pick an answer to see the explanation.
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.