The Final Overpayment Rule and Practical Steps for Compliance

By: James Saling

On February 11, 2016, the Center for Medicare and Medicaid Services (CMS) issued the final overpayment rule commonly referred to as the “60 Day Rule”. Physicians, labs, hospitals, and other providers that receive reimbursement under Part A or B must comply with the 60 Day Rule or face penalties under the False Claims Act.

The 60 Day Rule requires that overpayments (e.g., payment for coding errors) be reported and returned to CMS within 60 days after the date on which the overpayment was identified. Identification of the overpayment was addressed at length in the regulation.  The 60-day clock to identify overpayments starts ticking “when the person has, or should have through the exercise of reasonable diligence, determined that the person has received an overpayment and quantified the amount of the overpayment.”  Reasonable diligence means that the provider takes steps to uncover overpayments and steps to quantify the amount of the overpayment.Continue reading

The 8 Ways to Save Money or Make Money in 2014

      2014Now that we’re on other side of the holidays and solidly planted in 2014, it’s a great time to chart a new course.  Here are 8 things you can do that will make you money or save you money:

  1. Hire someone.  If you are a solo practitioner, are responsible for generating the revenue and also for leading your business, you will learn one clear thing:  it’s impossible!  It’s simply impossible to do both.  In business, if you are not growing, you’re sinking.  There is no such thing as maintaining the status quo.  If you can’t see how you can afford to do it, then you need to meet with your financial advisors, since at least some part of the work of your new hire will come off your plate.  It may even make sense to ask a local hospital to assist you in bringing in a new doctor.   Continue reading