Medicare’s 60 Day and 3 Day Window Rules – Overpayments

Medicare has now promulgated a penalty under the ACA through Section 6402(a) for failure to submit identified over payments within 60 days.

The 60 day clock begins when credible information of an overpayment exist. Overpayments can be the entire claim or a portion of the claim. One area of possible “reasonable diligence” falls with Medicare’s’ Three Day Window. As overpayments can be distinguished via 835 Remittance Advices, this area of potential overpayment could be more clear cut than other billing areas as to when the “clock begins.”

Failure to refund invoices paid by Medicare for the outpatient portion of a patient’s encounter under the 3 Day Window can result in a federal false claims act liability under 31 U.S.C. § 3729 (a) (1).

MedCom Solutions DRG Window Auditor™ uncovers 3 Day Window overpayments by auditing the providers’ 835 Remittance Advice. This software can be used as a reasonable diligence effort to identify potential overpayments by way of Medicare’s 3 Day Rule.

Stay compliant with MedCom Solutions

MedCom Solutions designs groundbreaking software that improves the processing of medical billing record information, ensures compliance, and leads to increased revenues year after year. Our Chargemaster, Pricing, and Compliance solutions have yielded hundreds of millions in net revenue for healthcare providers across the country.

To learn more, check out our solutions, visit our homepage or contact us today!