Question: What are the guidelines for refunding excess payments if we recently found out that we've been overpaid by the Centers for Medicare & Medicaid Services (CMS)?
RCI Subscriber
Answer: Regulations from CMS mandate a 60-day timeframe for refunding overpayments to federal entities. Although this rule may appear straightforward, it’s crucial to adhere to it as noncompliance could result in large fines.
While it’s true that every practice occasionally handles overpayments, the 60-day rule is designed to help practices identify systemic overpayment problems. Authorities still expect healthcare providers to monitor payments closely to identify any coding or billing discrepancies promptly for timely resolution. Any excess payments identified should be returned to CMS within the 60-day period, and the root cause should be addressed quickly to prevent similar overpayments in the future. Keep in mind that the countdown begins from the date the issue is identified, not the date of service or the date of the overpayment(s).
Remember: Addressing overpayments swiftly is crucial because if it’s found that you were aware of the overpayments and didn't return them in a timely manner, you could face penalties under the False Claims Act or the Civil Monetary Penalties Law. In the most severe case, your practice could be barred from participating in all federal healthcare programs.
Lindsey Bush, BA, MA, CPC, Development Editor, AAPC
