Tony Mira, CEO of Anesthesia Business Consultants, laid out the responsibilities of Medicare overpayments in a Feb. 8 blog post.
A provider has 60 days to refund an overpayment if it has been identified by the provider or billing agent. An identification includes the time necessary to investigate, confirm and quantify the amount of the repayment. According to the 2016 Medicare Physician Fee Schedule, six months have been deemed a reasonable limit for this process, Mr. Mira wrote.
For self-identified overpayments, the provider is obligated to send that amount back to Medicare no matter the amount. They also must include an explanation as to what caused the overpayment.
For CMS-identified overpayments, if the overpayment is more than $25, the Medicare administrative contractor must send a demand letter requesting repayment and the recoupment process begins.
If they disagree with CMS' determination of overpayment, providers can submit a rebuttal within 15 days that should provide evidence of the overpayment. This option does not stop the recoupment statement. Providers could also appeal the overpayment, which would stop the recoupment process.
Finally, Mr. Mira added, the lookback period on Medicare payments in six years.
Read more about CMS overpayments here.