In order to ensure that voluntary refund checks are credited accurately and in a timely manner, providers are required to complete the following overpayment refund form or a document containing similar information. Voluntary refunds are monies received not related to an open accounts receivable. In addition, please inform us if you are subject to a Corporate Integrity Agreement when sending in a voluntary fund for credit and for reporting to the Office of the Inspector General (OIG). Note: The acceptance of a voluntary refund does not affect or limit the rights of the federal Government or its agents from pursuing appropriate criminal, civil, or other administrative remedies as the result of an investigation of claims relating to the voluntary refund. Voluntary refund checks are not to be confused with credit balance repayments. A voluntary refund check is submitted when a provider discovers a global billing problem that affects a specific group of claims and has resulted in overpayment of those claims. Credit balance reporting and adjustment of a claim is appropriate when an individual claim or small group of claims have been overpaid, often as a result of an unexpected primary payment made by another payer. Office of Inspector General Initiatives The OIG, working with the Department of Justice (DOJ) and the Centers for Medicare & Medicaid Services (CMS), has two initiatives that help combat health care fraud and abuse, and encourage health care providers to comply with the rules and regulations of federal health care programs. These initiatives are:
Both initiatives are designed to ensure that the providers/suppliers refund inappropriately received Medicare monies back to the trust fund. Due to these new initiatives, it is anticipated that Medicare contractors will experience an increase in the number of voluntary refunds. Compliance Program Guidances are tailored to provide guidance, recommendations, and suggestions to health care providers/suppliers to assist in developing effective internal controls that promote adherence to applicable federal and state laws and the program requirements of federal, state, and private health programs. These guidances describe the fundamental elements of a compliance program. Among the suggestions and recommendations is that the health care providers/suppliers should establish an internal self-monitoring process that will aid them in detecting potentially fraudulent and/or abusive practices, which result in overpayments due to the Medicare program. Currently, Compliance Program Guidances have been published for the following entities: hospitals, home health agencies, clinical laboratories, and third-party medical billing companies. The OIG will be issuing compliance program guidance for additional entities in the future. Corporate Integrity Agreements (CIAs) are entered into between a health care provider/supplier and the OIG as part of a global settlement of a fraud investigation. Under the CIA (which can be for a period ranging from three to five years), the provider/supplier is required to undertake specific compliance obligations, such as designating a compliance officer, undergoing training, and auditing. The provider/supplier must report their compliance activities on an annual basis to the OIG, which is responsible for monitoring the agreements. Note: It is important that each claim involved in the overpayment be identified either on this form
Page Last Modified: 06/13/2007 |
