Did you know that UConn Health has an Overpayment Committee responsible for addressing systemic and substantial overpayments? UConn Health follows established rules and procedures to ensure proper billing for patient care services. Nevertheless, overpayments occasionally occur.
An overpayment occurs when UConn Health receives payment to which it is not entitled. An overpayment can happen because of incorrect coding, insufficient documentation, medical necessity errors, or processing or other administrative errors. Federal law requires Medicare overpayments be returned within strict timeframes – generally within 60 days of identifying and quantifying the overpayment amount. Failure to timely refund a Medicare overpayment may result in fraud liability or other civil or criminal enforcement action.
As a Medicare provider, UConn Health is required to investigate upon receiving credible information regarding a potential overpayment and in addition, must undertake proactive compliance activities to affirmatively monitor for potential overpayments. Proactive monitoring is especially important given the “known or should have known” standard that applies. What this means is that even without specific knowledge of an actual overpayment, UConn Health may be liable if the government determines we should have known that an overpayment was received.
At UConn Health, isolated overpayments are managed in the ordinary course of business by Clinical Revenue Services. Systemic or substantial overpayments, on the other hand, are managed by the Overpayment Committee. The Overpayment Committee is made up of individuals representing both John Dempsey Hospital and University Medical Group (UMG) in the departments of Revenue Integrity, Clinical Revenue Services, Information Technology (IT), Health Information Management (HIM), Healthcare Compliance and Audit and Management Advisory Services. The Committee reviews and analyzes potential overpayment issues that are significant and/or widespread. In such cases, the Committee must exercise reasonable diligence and expeditiously investigate to determine whether an overpayment was received and quantify the amount of any identified overpayment. In the case of a non-systemic or non-substantial overpayment issue, the Committee refers the matter to the appropriate department for processing (e.g., to issue a refund).
If you have knowledge of an actual or suspected overpayment, please contact The Office of Healthcare Compliance and Privacy. Alternatively, you may report the issue anonymously through the Reportline. For more information on overpayments, you can review UConn Health’s Overpayment Policy. You can also review UConn Health’s Policy on Fraud, Waste and Abuse Prevention and Education.