Foley & Lardner LLP Partner Judith Waltz is quoted in the article, “As COVID-19 Audits Ramp Up, Expect Broad Documentation Requests from Payers, HRSA,” in the Report on Medicare Compliance, published by the Health Care Compliance Association (HCCA), on the need for providers to brace for a large volume of unusually broad medical record requests as audits under the Health Resources and Services Administration (HRSA) COVID-19 uninsured program pick up steam.
Waltz said that when providers identify payment errors related to the HRSA uninsured program, they may go down a rabbit hole trying to resolve them. HRSA has a process for refunds that are due in full—when, for example, a provider was reimbursed for a service provided to a patient who turned out to have insurance—but some refunds are partial, she said.
“Then the choice has to be made: Refund in full with no way to submit a corrected claim or refund the delta and see if HRSA comes back to ask for more,” Waltz said. “This choice is one that will have to be made strategically as well as legally, considering all the facts (and the risk tolerance) associated with a particular situation,” she added.
Waltz is the co-chair of the firm’s Health Care Practice Group and Health Care Industry Team.