You're a Healthcare Provider Who Bills Medicare and/or Medicaid: Should You Self-Report an Overpayment?
The short answer is – yes! Under the law, you are required to self-report any overpayment you receive from Medicare or Medicaid and return the amount of the overpayment. You are also required to have a compliance program in place to diligently review your claims submissions and payments to discern whether there has been improper coding of services, billing for services not within the scope of practice for the professional for whom the services were billed, and things of that nature which result in the receipt of an overpayment. Once you discover ONE overpayment, you must investigate to try to uncover any other overpayments.
In general, a provider must self-report overpayments within sixty (60) days of when the overpayment has been quantified, but the deadlines are dependent upon whether the provider has instituted a compliance plan and has acted with due diligence in following the plan and investigating the matter. Self-reporting and return of overpayments can avoid enforcement action by the Centers for Medicare and Medicaid Services (CMS) and government contractors, monetary fines, and possible criminal prosecution. You should consult with competent healthcare counsel to make sure you have all the proper procedures in place. If you would like a consultation on this, or any legal matter, please do not hesitate to contact Scaringi Law at 717-657-7770.