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Monday, June 22, 2026

Increased Enforcement Means Need to Review Credit Balance Procedures - JD Supra

On December 10, 2021 a hospital in Illinois made the news when it was reported that Gibson Area Hospital had agreed to pay $292,000 to settle False Claims Act (“FCA”) allegations of failing to return overpayments received from Medicare, Medicaid, and other federal healthcare programs. Gibson City hospital to pay $292,000 to settle claims of Medicare fraud | Courts-police-fire | news-gazette.com The government alleged the hospital retained overpayments for various reasons, including overpayments that were: under $10, over a year old, duplicate payments, payments improperly applied to other claims, and/or overpayments that were not requested to be returned by payors at least three times.

In addition to this recent FCA settlement, State Medicaid Recovery Audit Contractors (“RACs”) around the country are routinely conducting credit balance audits. As just one example, one of the stated projects of the newly appointed RAC for South Carolina is to conduct credit balance audits. (2021-4-6) Medicaid Bulletin HMS RAC and CBA Contract FINAL.pdf (scdhhs.gov) This trend towards increased enforcement and oversight is a reminder that the correct handling of payor and patient credit balances is a burdensome but necessary undertaking.

What is a Credit Balance? The Centers for Medicare and Medicaid Services (“CMS”) defines the term “credit balance” concisely as “an improper or excess payment made to a provider as the result of patient billing or claims processing errors.” CMS-838 Medicare...



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