Any effective compliance program should be able to identify overpayments, whether that’s through the process of your regular billing audits, or through the process of investigations into reported incidents. While these overpayments can be anxiety-inducing, the problem doesn’t go away by ignoring it.
For some context, an overpayment is a payment that exceeds any regulation around proper payable amounts. When you (or Medicare) identify an overpayment, the overpayment immediately becomes a debt you owe the government. By law, the Centers for Medicare & Medicaid Services (CMS) are required to recover each of these identified overpayments. For Medicare overpayments, the federal government has three (3) calendar years from the date of payment to recover the overpayment. It should be noted that the statute of limitations starts from the date the reimbursement was made, and not the date the service was performed.
The sooner your organization is able to catch an instance of overpayment, the better. So once an overpayment is identified, an investigation should begin immediately. Because the sooner you can identify these overpayments, the sooner you’re able to remediate the issue, and minimize the payment owed. Otherwise, if your investigation and analysis determines the overpayments have occurred over an extended period of time, the total value of the refund could be significant.
Of course, in the case of a high volume of services, it might not be feasible to audit every single claim. But that doesn’t excuse you from accurately choosing audit sample sizes and extrapolating reliable results to determine, within a shadow of a doubt, the accurate overpayment amount you owe.
Whether you’ve uncovered overpayments in your career, or want to know exactly what to do in the event that you do find overpayments, I will be hosting a new webinar on November 18 at 1 PM ET, titled, “Don’t Overlook the Dangers of Overpayments,” where I’ll cover best auditing and investigation practices and let you know:
- When Overpayment Results Might Need to be Extrapolated
- What Tools Exist to Assist with Statistical Sampling and Extrapolating
- What Problems or Risks Might Arise with the Process of Extrapolation
I hope to see you there!