Pathology/Lab Coding Alert

Question: Our lab performed an internal audit and determined that we have received some overpayments from Medicare. What is the proper procedure to return those overpayments?

Codify Subscriber

Answer: CMS rules stipulate a 60-day limit on returning overpayments to federal agencies. The rule might seem simple, but you’ll want to ensure you comply since compliance failure could lead to 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 keep close enough tabs on payments to find any coding or billing issues early so they can be dealt with in a timely fashion. Any overpayments you discover should then be refunded to CMS within the 60-day window, and the underlying problem fixed to avoid future overpayments.

Tip: Remember that the clock starts ticking on the date the issue is discovered, not the date of service or payment.

Dealing with any overpayments quickly is important because if federal agencies discover that you knew about overpayments and failed to repay them promptly, you could be looking at penalties related to the False Claims Act or the Civil Monetary Penalties Law. In the worst-case scenario, your lab could be excluded from all federal healthcare programs.