Don’t overlook overpayments as a source of risk. According to the Centers for Medicare & Medicaid Services and the Medicare Learning Network (MLN), overpayments may be identified by CMS; a Medicare Administrative Contractor; or a provider, via self-identification.
CMS leans on providers to be keeping track of payments. “Through reasonable diligence, a provider can identify any overpayment and calculate the amount,” CMS warns in an MLN fact sheet. Section 1128J(d) of the Social Security Act requires providers to report and return any self-identified overpayment to its respective MAC within 60 days of identifying the overpayment, six years since the overpayment (six years constitutes the “lookback period”), or a corresponding cost report due date. Overpayments of $25 or more will spur a MAC to send a demand letter requiring repayment. More information about Medicare overpayments is at www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/overpaymentbrochure508-09.pdf.