Self-reporting Medicare and Medicaid overpayments.

Refunding a significant overpayment to the Medicare or Medicaid program can subject a healthcare organization to government scrutiny that can consume the time and energies of key staff members, risk potential litigation by shareholders, and possibly lead to severe sanctions. Delaying a refund, however, may precipitate even more costly consequences, such as triple damages and heavy monetary penalties. The government has stepped up its efforts to detect and punish fraud and abuse; therefore, providers should refund overpayments promptly. Failure to do so may constitute a crime, increase the likelihood of a whistleblower exposing the offense, or result in an increase in the amount of penalties imposed. Healthcare organizations can prevent overpayment abuses from occurring by following recommended procedures for making refunds, addressing underlying billing problems, and ensuring that senior management oversees the entire claims payment process.