Refund Policy

It is Connect Medical Group’ policy:

• to not knowingly retain any payments to which it is not entitled. To that end, reports or other information indicating that an overpayment may have been received must be immediately brought to the Compliance Officer’s attention.

•  to exercise reasonable diligence in timely investigating and quantifying any and all potential overpayments;

and

• to promptly report, return and explain in writing to the appropriate government agency, contractor or payor, any identified overpayments in accordance with applicable legal, regulatory, contractual and/or other requirements or guidance.

Note that governmental and private insurance payors may have different rules concerning when and how identified overpayments must be managed. For example, under the Federal Affordable Care Act statute (the “ACA”), Medicare and Medicaid overpayments must be reported, returned, and explained in writing within 60 days of the date the overpayment is identified. For Medicare Part A and Part B over-payments, regulations (effective March 14, 2016) provide that an overpayment is considered to have been “identified” when a person has or should have, through
the exercise of “reasonable diligence,” determined that an overpayment has been received and has quantified the amount of the overpayment. “Reasonable diligence” includes both proactive compliance activities conducted in good faith to monitor the receipt of overpayments, as well as investigations conducted in good faith and in a “timely manner” in response to obtaining “credible information” about a potential overpayment. Those regulations consider a “timely manner” to be at most six (6) months from receipt of credible information, except in extraordinary circumstances. Once an overpayment has been “identified,” the person must report, return, and explain in writing the overpayment within 60 days.

With regard to Medicaid, the company will report, return and explain in writing any identified Medicaid overpayments within 60 days of identifying the overpayment, consistent with applicable law, regulation and/or guidance, including that issued by applicable payor(s), contractor(s) and/or government agency (ies) (including, by way of example, the State Office of the Medicaid Inspector General (“OMIG)), as the same may be issued or amended from time-to time.
Any questions regarding when and how potential over payments are to be addressed by Connect Medical Group must be immediately brought to the attention of the Compliance Officer, who may consult with outside counsel, as necessary and appropriate.