Tonya Oliver Rose Discusses Potential Medicare Overpayment Changes

Thompson Coburn partner Tonya Oliver Rose was quoted in a Part B News article on a potential change to the 2025 Medicare Physician Fee Schedule (PFS). The change could impact the reporting and return of overpayments, possibly altering the timeline for refunds.

The rule extends the overpayment reporting and repayment deadline from 60 to 180 days. However, Tonya said that this timeframe may not always be sufficient.

Tonya noted that the proposed rule has no “absent extraordinary circumstances” language. “It simply says your clock starts ticking again after 180 days,” she says.

While that may be fine for some investigations, she cited the example of split/shared billing audits. In those instances, it “is not an issue where you can typically just look at data to find out whether a shared service was billed in compliance with the regulations,” said Tonya. “You might have to do extensive manual review of claims and the underlying medical record documentation to determine the nature and scope of any compliance concerns. I’ve had investigations that may start with one issue and then you realize it’s really multiple related issues that must be untangled.”

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