Category: General
In our last post about overpayments, we addressed who is at risk. Now we take a closer look at why most organizations are not paying closer attention to overpayments - and why they should be.
Timelines are really important when handling an overpayment. Focusing in on Medicare overpayments there are several deadlines you must consider. From the time an overpayment letter is received, you have 30 days to repay the amount due before interest will begin to accrue. If you decide you want to form a rebuttal or an appeal, you have 15 or 30 days respectively for filing those actions. If you do nothing, offset amounts will automatically be taken out of your future reimbursements. You can also request an Extended Repayment Schedule (ERS) - but there are timeframes for which you have to do that as well. Even if you don't receive an overpayment letter, but it comes to your attention that you were given an overpayment, there are rules about how long you have to initiate the refund (commonly known as the "60 day rule.")
If you don't repay, rebut or appeal the overpayment - you could get fined. In recent years, CMS's authority to revoke the billing privileges of providers or suppliers that show a pattern of "improper billing." Or, in a worst case scenario, you could be accused of fraud, which is a whole new set of challenges.
Typically, overpayment tracking is an entirely manual process. Most billing programs have no way to track these beyond a blanket credit memo to Medicare that gives little insight. Providers end up tracking in a separate spreadsheet. Or, because overpayments are a cost center some providers simply choose not to track and "trust" CMS to withhold the correct amounts. They figure it will cost less money in terms of effort.
If you are tracking overpayments in a spreadsheet, every time an offset happens, you have to go into the spreadsheet, match up the CCN or ICN and enter the amount and then ensure your calculations are correct. This is further complicated by the fact that offset amounts seem random. You'd think if the total claim is more than the total amount due in overpayment, that the whole amount would be taken. But it's not. It will be some portion.
Many claims can be listed on one overpayment notice, and since the recoupments are seemingly random - it's a lot to rely on for a human to track and errors are bound to be made. Another opportunity for error is simply version control. when you are running ad-hoc reporting in spreadsheets. Where does the latest version live? Is it on an individual's computer? A shared drive? Do you keep a separate spreadsheet by DCN number? How do you manage version control? There are so many ways to do this, and chances are it is not consistent across your organization.
The answer to minimizing the cost of handling overpayments and retaining a clear view into your full cash flow picture is to put in place a centralized, visible resource for tracking. Medforce's Overpayment & Refund Management App provides a consistent framework for handling and processing these transactions - whether it's an overpayment or a self-identified refund. All calculations are done by the software program - computers are, afterall, giant calculators... let them do their job. Alerts and notifications keep you informed of changes - or if a change hasn't happened in an expected length of time. The data is easily accessible for anyone with access rights, so there are no bottlenecks in getting the information you need when you need it. Plus, all documentation is grouped together in one spot.
As ERNs come in, and offset amounts are announced, the software can automatically process the overpayment, reducing the amount outstanding and giving you a clear picture of what is still owed. An audit trail keeps track over time and the outstanding overpayment, and a dashboard view can help you know real-time what remains outstanding on each ICN, DCN, or across the entire organization.
All of this is in service of reducing the costs of managing overpayments while maintaining the visibility and control you need to have a finger on the pulse of your cash flow at all times.
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