Authors: Paul W. Pitts Thomas W. Greeson

Here’s a scenario that radiology practices are likely to face at some point:

The practice has identified a billing error or a compliance problem impacting Medicare coverage that resulted in the practice having received an overpayment from Medicare. Although the fact that an overpayment occurred is known, the amount of the overpayment has yet to be determined. Practice leaders are aware that the Affordable Care Act requires repayment of an overpayment within 60 days of identifying it and that retaining an overpayment may result in significant penalties under the False Claims Act. While the practice is aware of the issue, the leadership is concerned whether a refund can be made within 60 days because a comprehensive audit must be conducted in order to determine the size of the overpayment.

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