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Tag: Josh Skora


Smart Talk

Overpayments: Create culture of compliance

August 22, 2016Josh Skora

A. In previous columns, I discussed how the 60-day overpayment rule presents a myriad of problems and questions that are sometimes difficult for an HME supplier to identify and address. However, the most effective remedy to overpayment problems is the implementation of and adherence to a robust compliance program. Overpayments will still arise, but the compliance program sets the stage for a corporate culture of compliance.The Affordable Care Act mandates that suppliers have compliance programs,...

Brown & Fortunato, Josh Skora, overpayments


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Smart Talk

Overpayments: Follow protocol

July 25, 2016Josh Skora

A. Typically, suppliers report and return overpayments to the DME MAC of jurisdiction. Each DME MAC has a standard overpayment refund form. The supplier simply provides information and submits a refund check. Suppliers must indicate a reason for the overpayment. A few of the available reasons are: billed in error, insufficient documentation, services not rendered and medical necessity. The refund is a dollar-for-dollar payment. No penalty is assessed.  On the other hand, in cases that involve...

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Overpayments: Exercise reasonable diligence

May 23, 2016Josh Skora

A. The Affordable Care Act requires a person who has received an overpayment to report and return the overpayment to the government.For HME providers, overpayments must be reported and returned within 60 days after the date on which the overpayment was identified. This led to many unanswered questions. What does “identified” mean? If a provider uncovers one overpaid claim, is it required to investigate all related claims? When does the 60-day clock start? How far back must the provider...

Brown & Fortunato, Josh Skora, overpayments


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