The Duty to Self-Report Overpayments

The current Fee-For-Service (FFS) payment model for reimbursing healthcare providers functions as a pay-and-chase model, meaning you get paid for services under the presumption that the provider represented the services they rendered accurately and in accordance with various regulatory requirements. When organizations bill for services, they are reimbursed on a good-faith basis with the expectation that clinical documentation supports the services reported. This pay-and-chase model creates a false sense of security for healthcare providers that mistakenly assume because they got paid for something means they are doing everything compliantly. This assumption could not be further from the truth. Just because you got paid, doesn’t mean you billed services compliantly. Clinical documentation deficiencies, coding and billing errors, compliance risks, and overpayments are most often identified in post- payment audits that occur retrospectively (meaning after the services were already paid for by a third-party). Payer Audits and Recoupments are insidious and can lead to catastrophic consequences for healthcare providers. Many healthcare organizations fail to self-report and refund identified overpayments, which is mandated and required by the Social Security Act. Overpayments can occur for a number of reasons, including coding errors, insufficient documentation, inadequate supervision, lack of medical necessity, ineligible billing provider, etc.

This webinar will define overpayments in various examples, unpack the requirements for self-reporting, unravel the pathways for which self-reporting can take place, spotlight the consequences of not self-reporting, discuss timelines and look-back periods for self-reporting, and so much more.

Webinar Objectives

This webinar will cover the various types of overpayments, unpack the various pathways involved in self-reporting, discuss timelines for self-reporting spotlight potential consequences involved with failing to self-report, identify relevant action protocols, and discuss best practice tips for self- reporting to ensure your organization is compliant.

Webinar Agenda

1. Understand how to identify an overpayment that qualifies for self-reporting
2. Recall the mandatory obligations for self-reporting overpayments
3. Recognize current trends and audit targets in healthcare compliance
4. Recall overpayment and voluntary refund protocols
5. Recognize when the OIG self-disclosure protocol may be appropriate
6. Understand timelines and look-back periods for self-reporting

Webinar Highlights

1. Define what an overpayment is and how to identify them within your organization
2. Outline various examples of overpayments
3. Review the various pathways involved in self-reporting overpayments
4. Discuss potential consequences that can occur when you fail to self-report
5. Deconstruct current trends and audit targets in healthcare compliance
6. Discuss timelines for self-reporting overpayments
7. Review the look-back periods that overpayments are subject to
8. Discuss target and probe audits and how they can be useful in self-reporting
9. Review the overpayment and voluntary refund protocols
10. Discuss when the OIG self-disclosure protocol may be appropriate

Who Should Attend

• Medical Coding Specialists
• Medical Billing Specialists
• Medical Auditing Specialists
• Private Practice Physicians
• Managed Care Professionals
• Operations Leadership
• Practice Administrators
• Office Managers
• Compliance Officers/Committees  
• Chief Medical Officer