Six Year Look-back Audits and 60 Day Overpayment Rule
Course Description:
The Affordable Care Act includes the 60-day overpayment rule, which requires suppliers to refund overpayments within 60 days of identification. What many suppliers aren’t aware of though is that if an overpayment is identified, either internally or externally, suppliers are mandated by law to perform a six-year lookback audit. This overly burdensome process has impacted hundreds of suppliers around the country and now that the TPE program has migrated to post payment reviews during the pandemic, this could impact even more suppliers. Even worse, if suppliers do not comply with this rule, they are at risk of false claim penalties. This panel will provide an overview of what is required of a supplier who is faced with an overpayment, how to manage the situation, what risks are associated with the overpayment rule and most importantly, how to mitigate your risk when dealing with this process. Lastly, the panel will provide real life case studies of suppliers who have experienced this challenge and the outcomes.
Learning Objectives:
- Identify situations in which the 60-day overpayment rule is applicable
- Understand what steps a provider must take in the event of an overpayment
- What can providers do to mitigate risk associated with the 60-day overpayment rule
- Review the 60-day overpayment rule and the six-year lookback obligation
- Know the steps that suppliers can take to reduce the risk of being subjected to the 60-day overpayment rule
- Set out the steps the supplier should take to successfully fulfill its obligations under the rule
Areas Covered in the Session:
- Key Provisions
- Meaning of Identification
- Lookback Period
- How to report and return overpayments
- Identification of overpayments
- Proactive compliance activities
- Investigative activities – RACs and UPICs
- Benchmark for Investigation
- 60-day to Refund
- Six Year Look Back Period
- No minimum monetary threshold
- OIG Report
- What OIG Found?
- What OIG Recommended?
- Sleep Management’s Response
- Identify, Report, and Return
- Contractor Instructions
- OIG Recommend
- Timelines
- Process
- Appealed claim to MAC Redeterminations and QIC, if necessary
- Identify scope
- Claims data universe
- Sample sizes
- Determine audit components
- Order
- Proof of delivery
- Refill request
- Continued need
- Analysis of findings
- Is there a loss to the government
- Identify overpayment
- Extrapolation
- Summary report
- Submit to MAC
- Contractor Response
- Outcomes
- Impact
- Medicaid Lookbacks
- Concerns
- UPIC Language
- Federal Register
- Final Rule
- Legal Implications
- Future Forecast
- Prepare Your Practice
- What if this happens to me?
Suggested Attendees:
- Revenue Cycle Team-coordinator of audit tracking
- Billing Managers
- Owners
- Operations Staff Team
- Compliance Officer
- Physicians
- Practice Managers
- C-level executives
- Medical billers
- Medical Coders
- Office staff and Billing Managers
- Medical Billing Companies
- Providers’ Office Staff
- Hospital Revenue Cycle Staff
About the Presenters:
Kelly Grahovac serves as the General Manager for The van Halem Group where she focuses on audits, appeals, education and training, and business development, in addition to management duties. Kelly is a known lecturer in the DME industry, speaking at national conferences, state associations, and for private events. Kelly came to The van Halem Group with 10 years of experience at one of the nation’s leading Medicare contractors where she worked for the Durable Medical Equipment Regional Carrier (DMERC), Qualified Independent Contractor (QIC), and A/B Medicare Administrative Contractor (MAC). Her various roles with Medicare include working as a senior provider relations representative, QIC Adjudicator and Training Specialist. Kelly has in-depth knowledge in Medicare appeals, policy, education, and training. Kelly is an active member of the Health Care Compliance Association (HCCA) and currently serves on the Medicare DME MAC Jurisdiction D Advisory Council, as well as the National Supplier Clearinghouse (NSC) Advisory Council. Kelly is also an active board member for the South Carolina Medical Equipment Suppliers Association (SCMESA). In addition to her client work at The van Halem Group, Kelly is also a contributor to several industry publications nationally.
Additional Information:
System Requirement:
- Internet Speed: Preferably above 1 MBPS
- Headset: Any decent headset and microphone which can be used to talk and hear clearly
- For more information, you can reach out to the below contact:
Toll-Free No: 1-302-444-0162
Email: care@skillacquire.com
Snippet From Our Previous Session:
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Testimonials:
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Melissa Preston, Health Information Management Staff
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Sandie Fowler, Out of Network Billing Staff
"Great presentation. Able to do during the day. Timing was great"
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