Want to avoid Medicare over-payments? Watch out for these potential issues.
There are few things as frustrating as Medicare over-payments, which are unfortunately a common issue for any U.S. healthcare provider, including radiologists. This happens when Medicare reimburses a provider or supplier more than what they should under Medicare statute and regulations, and that provider then becomes responsible for paying back the over-paid amount.
Attorney W. Kenneth Davis, Jr. addressed this issue at the Radiology Business Management Association (RBMA) PaRADigm Shift 2020 virtual meeting. His presentation discussed several tricky Medicare compliance areas that may lead to over-payments:
- The Stark Law: This federal law prohibits referrals to facilities where the radiologist or an immediate family member have a financial interest. Set a protocol that does not allow referrals from family members. All radiologists in the practice should regularly update professional changes for family members.
- Telehealth: Billing for telehealth can be complicated, so be sure that radiologists are licensed in the state where the patient’s imaging study was conducted. Bill the correct Medi.care-approved contractor for all services.
- Non-radiologists: Radiology assistants and radiology physician assistants are not considered Medicare Part B suppliers and cannot be billed for like other healthcare professionals.
Get the full list from Diagnostic Imaging.
Under the Affordable Care Act, over-payments must be repaid within 60 days of being identified. Otherwise, your practice could be liable for some huge penalties under the False Claims Act.
A 2015 article from Radiology Business describes several scenarios that highlight the importance of following that 60-day repayment window, and of having a robust program for compliance, internal monitoring, and auditing.
Medicare also offers a fact sheet about its over-payment collection process in the form of a downloadable PDF.
Staying on the right side of compliance and liability is vital for any radiology practice. The right enterprise imaging solution can help improve communications, cost efficiency, and patient safety to keep you profitable and compliant.