Cardiology Coding Alert

Question: We’ve heard that the Centers for Medicare & Medicaid Services (CMS) says we should return any overpayments to federal health programs within 60 days. But with so many billing and compliance rules, we haven’t paid much attention to this one. What do we need to know about it?

South Carolina Subscriber

Answer: You are correct — CMS issued a rule in 2016 setting a 60-day limit on returning overpayments to federal agencies. (There was a proposal to change the language in 2023, but this was not adopted.) The important thing to remember is that while the rule might seem simple, it represents some big changes related to compliance — and a practice that fails to comply might face huge penalties.

The reasoning: Every practice occasionally handles overpayments, but the 60-day rule is designed to help practices identify systemic overpayment problems. Federal officials expect providers to sniff out coding or billing issues, and to move swiftly to address those issues. Any overpayments you discover should then be refunded within the 60-day window, and the underlying problem is fixed to avoid future overpayments.