Lexology July 24, 2024
What steps must a radiology practice undertake if it has uncovered a possible billing error or a compliance problem impacting Medicare coverage, such that it appears that the practice has received a possible overpayment from Medicare? Although the practice believes that a possible overpayment has occurred, confirmation of that fact and calculation of the amounts of any overpayments has yet to be determined. The practice leaders are aware that the Affordable Care Act contained a requirement for repayment of Medicare overpayments within 60 days of identifying it and that retaining any overpayments may result in significant penalties under the Federal False Claims Act (FCA). But they may be uncertain on how to proceed, and in what time frame must they...