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An effective compliance program will result in you making refunds. But many organizations cause more pain than necessary by refunding improperly. Whether it is going to the U.S. Attorney when a refund to the Medicare Administrative Contractor will do or refunding six years of Medicare reimbursement when four is sufficient, many organizations unnecessarily penalize themselves when refunding money.
Many organizations fail to understand how to interpret NCDs, wrongly assuming that if the NCD covers a treatment for specific diagnoses, that always means other diagnoses are NOT covered. Most organizations fail to realize that LCDs are not legally binding and that it is never necessary to refund because of an LCD.
Our April Health Law Webinar discussed the best strategies for refunding money without OVER-refunding money.
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