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Last month, SHM sent a letter [PDF] to Marilyn Tavenner, acting CMS administrator, calling for the look-back period to be halved to five years. SHM president Shaun Frost, MD, SFHM, FACP, wrote that the extended time frame could be problematic for hospitalists and other physicians.
"SHM was compelled to provide guidance on behalf of its members to protect them from the undue burden proposed in the Reporting and Returning of Overpayments rule," says SHM CEO Larry Wellikson, MD, SFHM. "Though SHM supports the goal of reducing overpayment, asking hospitalists and their hospitals to look back through 10 years of records to identify areas of overpayment is unreasonable."
CMS announced that the 10-year period was chosen to coincide with the statute of limitations of the False Claims Act. But SHM leaders note that most laws governing Medicare overpayments generally don’t exceed six years. Potential problems with the extended audit period include physicians who have moved on from a job and "may no longer have access to the documentation necessary for an adequate 10-year audit," according to the letter.
SHM also is pushing for CMS to include a calculation of "burdens and costs associated" with the extended look-back period in the proposed rule.
"SHM believes a measurement of the cost for all providers to perform a full 10-year audit would more fully illustrate the extent of the burden presented by the proposed look back period," Dr. Frost wrote in the letter.