7 ways to clean up credit balances before they become a compliance problem

A credit balance sitting on the books can look like found money. It is anything but. Whether it belongs to a patient, a commercial payer or Medicare, an unworked credit is a liability with a clock attached, and the clocks are getting shorter. CMS revised its 60-day overpayment rule effective January 1, 2025, redefining when an overpayment is “identified” to match the False Claims Act’s “knowingly’ standard.

States are moving too. Florida now requires practices to refund patient overpayments within 30 days of determining one exists, with administrative fines and professional discipline on the table, and state unclaimed property auditors have made health care a favorite target. One Tennessee cardiology group paid $2.9 million in penalties after failing to refund overpayments.

The irony is that practices working hard to collect at the point of service are generating more credit balances than ever, since estimated payments and actual adjudication rarely match. Here are seven places to start cleaning up.