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JotPsych Notes
JotPsych Notes

Recoupment limits for paid claims in five states and Medicare

Texas, Florida, and other states limit how long an insurer they regulate can ask for money back. Check which limit applies before you repay.

Chris Hume
Chris Hume
Head of Growth and Operations, JotPsych

Recoupment means a payer takes back money it already paid you on a claim. Which limit applies to you depends on the payer: a state-regulated insurer, Medicare, Medicaid, or an employer that pays claims from its own funds.

Recoupment limits for state-regulated insurers in five states, Medicare, and Medicaid recovery audit contractors
the time limit in each law and the cases it leaves out, read October 2 and 3, 2026
WhoTime limitThe limit doesn't apply to
Texas insurers180 days after an in-network provider receives payment, to send written noticeNo exception listed
Maryland insurers6 months after payment; 18 months for coordination of benefitsFraud, duplicate claims, improper coding if the insurer sent its coding guidelines at least 30 days before the visit, and yearly risk-sharing or two-sided incentive adjustments
California insurers365 days after paymentFraud or misrepresentation by the provider
New York insurers24 months after you receive paymentA reasonable belief of fraud or other intentional misconduct, abusive billing, recovery that a self-funded plan requires or asks for, government programs, public employee plans, and offsets against an underpayment you claim
Florida insurers30 months after payment; 12 months for physicians and psychologistsProviders convicted of fraud
Medicare1 year after the claim decision, for any reason; 4 years for good causeFraud or similar fault
Medicaid recovery audit contractors3 years after the claim dateOlder claims the state approves

Each limit comes from that state's insurance law, Medicare's reopening rule, or the federal rule for Medicaid recovery audit contractors. Each limit runs from the date its row names, so count from that date, not from the day the request arrives.

  1. Find the row for the payer that asks. Texas gives an insurer 180 days after you're paid to send written notice, if you're in its network, and you then have 45 days to arrange repayment. The insurer can't recover until your appeals are done. In another state, ask your state's insurance department whether its law sets a limit.
  2. Check what each limit covers. Florida splits its limit by license. The limit is 12 months for a physician or psychologist, and 30 months for a counselor, social worker, or marriage and family therapist. Maryland allows 18 months for coordination of benefits. New York's limit excludes recovery that a self-funded plan requires or asks for. California's limit excludes misrepresentation.
  3. Check Medicare's and Medicaid's limits. Medicare can reopen your paid claim within 1 year for any reason, or 4 years for good cause, such as new and material evidence or an obvious error. Medicare has no limit for fraud or similar fault. Medicaid's recovery audit contractors can't review your claims more than 3 years old unless the state approves.
  4. Ask each payer whether a patient's plan is self-funded. In a self-funded plan, the employer pays your claims from its own funds. Under the Employee Retirement Income Security Act (ERISA), a for-profit company's self-funded plan isn't “deemed to be an insurance company” for state insurance law. So your state's limit may not apply.
  5. Read your network contract when a self-funded plan asks. Your patient's employer often hires an insurer or a third-party administrator to run its self-funded plan. UnitedHealthcare's guide for the plans it insures or runs gives you 30 days to dispute a request, unless law or your contract sets another limit.

In KFF's 2025 survey, 73% of covered workers at private for-profit companies with 10 or more workers were in self-funded plans.

Covered workers in self-funded plans at private for-profit companies, 2025
share of covered workers at private for-profit companies with 10 or more workers
73%Self-funded27%Not self-funded

From the note to Figure 10.5 of KFF's 2025 Employer Health Benefits Survey. Check the plan type for each commercial patient before you rely on your state's limit.

Your notes have to support each claim until the longest limit that applies ends, so write each note for a reader who opens it years from now.

Export chart in JotPsych turns the notes you pick for a patient into one PDF for your dispute.

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Sources:
  1. Texas Insurance Code 1301.132, Overpayment, with 1301.069 on out-of-network care (preferred provider plans; 843.350 and 843.351 set the same for HMOs); read October 3, 2026.
  2. Maryland Code, Insurance 15-1008, subsections (b), (c), and (e); read October 3, 2026.
  3. California Insurance Code 10133.66, subsection (b); read October 3, 2026.
  4. New York Insurance Law 3224-b, subsection (b)(3) and (4); read October 3, 2026.
  5. Florida Statutes 627.6131, subsections (6) and (18), with chapter 490 for psychologists and chapter 491 for counselors, social workers, and marriage and family therapists (641.3155 sets the same limits for HMOs); read October 3, 2026.
  6. National Association of Insurance Commissioners, Insurance Departments, the directory of state insurance departments; read October 3, 2026.
  7. 42 CFR 405.980, reopening of initial determinations; read October 2, 2026.
  8. 42 CFR 455.508, Medicaid recovery audit contractors; read October 2, 2026.
  9. 29 U.S.C. 1144, ERISA section 514(b)(2)(B); read October 2, 2026.
  10. UnitedHealthcare, 2026 Care Provider Administrative Guide, effective April 1, 2026: scope, and Chapter 10, overpayments and disagreement.
  11. KFF, 2025 Employer Health Benefits Survey, Figure 10.5 and its note (73% of covered workers at private for-profit firms are in self-funded plans) and its definition of a self-funded plan; a survey of 1,862 private and non-federal public employers with ten or more workers, January to July 2025; read October 3, 2026.