Home Health & Hospice Week

Industry Note:

Watch Out For This OIG Work Plan Item

Medicaid overpayments could get you in trouble this year.

Are you hanging on to a Medicaid overpayment and maintaining it as a credit balance? The OIG may want to chat with you in 2012.

The HHS Office of Inspector General has some big plans next year for reviewing your Medicaid claims, and they span the whole spectrum of issues, according to the OIG's 2012 Work Plan. That includes overpayments.

When you receive an overpayment from Medicaid, you are expected to send it back -- the amount of time you can spend before you refund the money varies from state to state, but if you are aware of an overpayment, you must pay it back. And the OIG is looking for practices that haven't been holding up their end of that deal.

"We will review patient accounts of providers to determine whether there are Medicaid overpayments in the accounts with credit balances," the Work Plan indicates. "Previous OIG work found Medicaid overpayments in patients' accounts with credit balances. Medicaid is the payer of last resort and providers are able to identify and refund overpayments received."

Translation: All other available payers "must meet their legal obligation to pay claims before the Medicaid program pays for the care of an individual eligible for Medicaid," CMS says in its "Third Party Liability Overview." Therefore, if you erroneously bill Medicaid first, and then another payer reimburses you for what Medicaid has already paid you, you must repay Medicaid that amount.

The OIG 2012 Work Plan is online at http://go.usa.gov/93X.

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