More stringent federal requirements on overpayments present healthcare organizations with imperatives for addressing risk and liability. Provident Management Consulting’s (“Provident”) 60-Day Repayment advisory solution assists with implementation of improved controls to ensure that identified overpayments are reported and returned in a timely manner. Our solutions can help mitigate risks that can negatively affect cash flow and severely damage the organization’s reputation.
OVERVIEW
- Responds to the new and more stringent overpayment obligations and compliance challenges already in effect
- Creates a process for resolving overpayments before they trigger False Claims Act liability
- Mitigates risk and protects the reputation of providers
- Creates a proactive structure for continuous improvement
Changes in the Patient Protection and Affordable Care Act (PPACA) and the False Claims Act (FCA) have made repayment obligations more stringent, increased uncertainty in some areas, and made penalties more severe. As of March 2010, retaining overpayments from federal programs past the date on which they become an obligation is considered fraudulent activity, enforceable under the FCA. Noncompliance can result in civil penalties of $5,000 to $10,000, plus three times the overpayment amount, regardless of overpayment size.
Legal interpretations of the technical aspects of the requirements vary and guidance has been limited, however, these provisions are already in place, and it is imperative for leadership to respond with a formal, effective, interdisciplinary approach that extends across the organization.
Provident’s 60-Day Repayment advisory solution provides the analysis, methodology, and structure to help you evaluate and implement improved controls to ensure timely reporting and repayment, minimize or eliminate potential exposure under the FCA, and safeguard your reputation.
A COMPREHENSIVE APPROACH
Key components of our solution include:
Organizational Accountability
Our solution includes designation of responsibility for identifying, reporting, tracking, and working overpayments to create shared accountability between revenue cycle and compliance leadership.
Documented Criteria
We work with providers on development and implementation of policy, procedure, and controls to create transparency in documentation, reporting, and accountability. We work with the client’s compliance staff and counsel to help establish the criteria to define an overpayment and to design procedures and controls to determine when an overpayment is considered “identified.”
Identification and Timely Response
We assist with operational, systems, and reporting improvements to facilitate timely remediation and response related to identified overpayments and reduce potential FCA liability for the organization.
Continuous Improvement
We help clients identify, track, and act on trends or patterns that lead to overpayments, creating a proactive, interdisciplinary framework to reduce overpayments, mitigate risk, and promote continuous improvement.
WHAT SETS US APART
Provident’s depth of experience in healthcare operations, compliance, data analysis, and revenue cycle makes us uniquely qualified to provide valuable analysis and guidance.
Our team members have professional backgrounds working in provider organizations, law firms, and government agencies. We have unmatched knowledge of organizations across the healthcare spectrum, from single hospitals to healthcare systems, academic medical centers, and physician practices.