Monday, January 31, 2011

Stay Away From A 'Finders Keepers' Overpayment Mentality

Recently, we found out that a patient overpaid us on her copay. We gathered $50, which was the last copay we had on record. It turns out that the patient's plan changed, but she is still under the same payer. However, her copay is now only $25 for an office visit. In this situation, can we just credit her account or do we need to issue a refund?
Well, you certainly need to issue a refund to the patient; however how you do that depends on the patient. As soon as you discover that a patient has overpaid you, your practice should notify the patient.

You cannot hold onto the money indefinitely.

You can credit the patient's account; however only if the patient agrees to that. If the patient will be returning to your office you can suggest that you apply the overpayment as a credit toward the patient's co-payment for the next visit. If the patient does not want to apply it toward a future visit, however, you must return the overpayment.

You should provide two options:



  • A credit on the patient's account that you will apply to future services

  • A refund of the overpayment.

    Tip: You may find it easier to just send the overpayment amount back to the patient with a letter explaining the situation, rather than notifying the patient and discussing options. Go for whichever process works best for your practice.

    Bottom line: You can't and shouldn't keep an overpayment – from a patient or a payer. That practice may land your provider in big trouble. The agreement to return to any overpayments is fundamental to a provider's eligibility to participate in the Medicare program.

    Section 1866(a)(1)(C) of the Social Security Act (42 U.S.C. § 1395cc) needs participating providers to provide information about payments made to them and to refund any monies incorrectly paid. The 2010 Patient Protection and Affordable Care Act creates new obligations under the False Claims Act (FCA) whereby a Medicare provider who fails to timely report and refund an overpayment may be subject to substantial damages and penalties.

    For further details, sign up for a medical coding guide like Supercoder.
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