As a sequel to our article “T Minus Sixty Days and Counting” in the Winter 2010, issue of Corridors, this article discusses some practical procedures for hospitals and other providers to handle overpayments and repayments. In the world of medicine, the “golden hour” is that small window of opportunity within which the lives of cardiac, stroke or trauma patients can be saved. Similarly, providers who are overpaid by Medicare or Medicaid have their own “golden hour” for reporting and returning such payments. Fortunately, providers do not have just an hour to respond concerning overpayments but instead have a golden 60 days. But the idea is the same —immediate action is the key to survival.
The Patient Protection and Affordable Care Act (PPACA) has instituted a “60-day rule” that requires any person who has received a Medicare or Medicaid “overpayment” to which the person “is not entitled” to report such overpayment and return it within “60 days after the date on which the overpayment was identified.” There is a separate rule for cost reports, which we do not address here.
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