What must an entity do when errors result in mere overpayments?

When errors result in mere overpayments, the ethical and regulatory obligation for an entity is to voluntarily identify, disclose, and refund those overpayments. This practice aligns with principles of transparency and accountability in healthcare financial management.

By proactively addressing overpayments, an entity demonstrates compliance with both legal requirements and the standards set forth by various regulatory bodies, such as the Centers for Medicare & Medicaid Services (CMS) and the Office of Inspector General (OIG). These guidelines emphasize the importance of returning overpayments as a means to maintain trust in the healthcare system and uphold integrity in billing practices. This approach also helps prevent potential legal repercussions that could arise from withholding identified overpayments, thereby safeguarding the entity's reputation and avoiding fines or penalties.

Waiting for an audit to occur is not advisable, as it could lead to prolonged financial discrepancies and a lack of accountability. Consulting with external auditors may provide additional insights but does not relieve the entity of the responsibility to act upon the discovery of overpayments. Ignoring the overpayments altogether is not a viable option, as it would violate compliance obligations and could lead to significant issues in the future.