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Integrity Means Returning Overpayments

Kate Traynor

While some health care providers might rationalize their keeping an overpayment from a federal health program as compensation for other seemingly low reimbursements, providers who have corporate integrity agreements with the Department of Health and Human Services (HHS) must not consider the situation so casually.

Integrity agreements are the government's way of allowing health care providers who were caught submitting fraudulent claims to a federal health program such as Medicaid to continue doing business with HHS. The health care providers and HHS's Office of the Inspector General (OIG) typically negotiate an integrity agreement lasting five years, during which they can continue to receive payments for taking care of patients covered by federal health programs.

As part of these agreements, health care providers must usually send OIG an annual report documenting all overpayments received from federal health programs. These health care providers must promptly notify HHS programs about overpayments throughout the year and return the money, OIG recently stated in its answers to frequently asked questions about corporate integrity agreements.

OIG allows health care providers to explore with payers the possibility of keeping an overpayment to offset legitimate underpayments. However, the full overpayment total must still be listed in the annual report to OIG.

According to OIG, over 400 health care providers currently operate under corporate integrity agreements or other integrity provisions.