Practice Management Alert
Perform Due Diligence for Medicare Overpayments
Question: Who is responsible for identifying and correcting overpayment in any Centers for Medicare & Medicaid Services (CMS) reimbursement? Is there a lookback period or is any claim ever paid fair game? South Dakota Subscriber Answer: According to CMS and the Medicare Learning Network (MLN), overpayments may be identified by CMS; a Medicare Administrative Contractor (MAC); 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. Find out more at the fact sheet here, www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/ downloads/overpaymentbrochure508-09.pdf.
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