Stay Away From A 'finders Keepers' Overpayment Mentality
Scenario: We found out that a patient overpaid us on her co-pay
. We gathered $50, which was the last co-pay we had on record. It turns out that the patient's plan changed but is still under the same payer. However, her co-pay is now only $25 for an office visit. In this case, can we just credit her account or do we need to issue a refund?Answer: You do need to issue a refund to the patient; however how you do that is up to the patient. As soon as you find out that a patient has overpaid you, your practice should notify the patient.
You cannot hold onto the money for an indefinite period of time.
You can credit the patient's account, however only if the patient agrees to that. If the patient will be returning your office you can suggest that you apply the overpayment as a credit toward the patient's co-payment for the next visit. But again if the patient does not want to apply it toward a future visit, you must return the overpayment.
You should offer two options:
A credit on the patient's account that you'll apply to future services
A refund of the overpayment
You may find it easier to just send the overpayment amount back to the patient with a letter explaining the situation, rather than notifying the patient and discussing options. Go for whichever process works best for your practice.
Bottomline: You cannot and shouldn't keep an overpayment from a patient or a payer. That practice may land your provider into big trouble. The pact to return any overpayments is fundamental to a provider's eligibility to participate in the Medicare program. Section 1866(a)(1)(C) of the Social Security Act (42 U.S.C. 1395cc) calls for participating providers to furnish information about payments made to them and to refund any payments paid incorrectly. The 2010 Patient Protection and Affordable Care Act creates new obligations under the False Claims Act (FCA) whereby a Medicare provider who fails to report timely amd refund an overpayment may be subject to substantial damamges and penalties.
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