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for the overall financial benefit of your facility, especially in this era of
healthcare reform cost-saving initiatives.
Make additional upgrades
When new surgeons arrive, don't copy the preference card from
another surgeon in their specialty group. Instead meet with the sur-
geons to understand their individual preferences and build cards
3
We finally know what you should do in the event Medicare overpays you, based on CMS's
long-awaited final rule (osmag.net/dEPuT9) regarding Medicare Parts A and B overpay-
ments:
• 60 days. Facilities are required to report and return any overpayment within 60 days of
identifying it and calculating how much they owe CMS.
• 6 years. While CMS initially asked facilities to go back through 10 years' worth of claims
to look for overpayments, the finalized rule shortened that period to 6 years after critics called
the initial proposal too burdensome.
CMS initially warned facilities 4 years ago that they were on the hook for any Medicare
overpayments, but it just last month clarified how and when those excess funds received
from Medicare Parts A and B must be paid back. As part of the new regulation, facilities
should implement some form of compliance programs, CMS says, which can include things
like period claims monitoring or retrospective internal audits. Facilities that ignore overpay-
ments are subject to liability under the False Claims Act, which could mean facing financial
penalties or future exclusion from Medicare and Medicaid programs. To report and return the
payment, the final rule lists several options, including using an applicable claims adjust-
ment, credit balance, self-reported refund or another "appropriate process."
— Kendal Gapinski
PAID TOO MUCH?
CMS Clarifies Overpayment Return Rules
Business Advisor
BA
