The relatively new 60-Day Rule affects all Medicare and Medicaid providers regardless of specialty, size or type, and nailing down the exact date to begin your 60-day countdown is one of the most confusing compliance aspects — although other rule components can easily trip you up as well.

The rule may seem straightforward — you must refund Medicare overpayments within 60 days — but complying with this requirement is anything but. Keep in mind the consequences you’ll face for noncompliance, including fines of $11,000 (or more) for each overpayment you don’t correctly report and return … just for starters.

According to Medicare, two events must occur to trigger the 60-day countdown:

• Determining that there has been a potential overpayment, and
• Quantifying the potential overpayment’s total amount.

Consequently, if you don’t have a process in place to identify overpayments, you need to establish one now. This process should include both investigating and quantifying the suspected overpayment to specifically finalize the amount and ensure timely repayment. You are responsible to find and return Medicare overpayments, and failing to do so will leave you facing serious penalties and fines.