Overpayments Uncovered: Medicare and Commercial Payer Policies for Identification, Reporting, and Refund

Overpayments present one of the most significant compliance and financial risks for healthcare organizations, particularly as both Medicare and commercial insurance carriers continue to expand post‑payment audit activity, data analytics, and recoupment efforts. Many organizations struggle not only with identifying potential overpayments, but also with understanding when an overpayment is considered “identified,” what triggers an obligation to refund, and how payer‑specific rules differ across government and commercial plans.

This educational webinar provides an in‑depth, payer‑specific review of overpayment policies and refund requirements for Medicare, UnitedHealthcare (UHC), Cigna, Aetna, and Blue Cross Blue Shield of North Carolina (BCBS NC). The program is designed to help coding, billing, revenue integrity, and compliance professionals clearly understand their obligations when overpayments are discovered through audits, internal reviews, payer correspondence, or data analysis activities.

A significant focus of the session will be placed on Medicare’s 60‑day overpayment rule, including how and when the repayment clock begins, what constitutes “reasonable diligence,” and the compliance risks associated with delayed reporting and refunds. The session will then compare Medicare requirements to commercial payer policies, highlighting differences in refund timelines, contractual considerations, self‑disclosure expectations, and payer‑specific refund submission processes.

Attendees will also explore common overpayment triggers such as incorrect coding, medical necessity denials, duplicate billing, modifier misuse, documentation deficiencies, and post‑payment audit findings. Practical guidance will be provided on how to establish internal workflows for identifying, tracking, investigating, and refunding overpayments in a consistent and defensible manner.

By the end of this session, participants will walk away with a clear understanding of payer expectations, real‑world compliance considerations, and actionable strategies to reduce organizational risk related to overpayments.

Webinar Objectives

The objective of this session is to provide healthcare professionals with a clear, practical understanding of overpayment identification, reporting, and refund obligations across Medicare and major commercial insurance carriers, including UnitedHealthcare, Cigna, Aetna, and BCBS North Carolina.

Specifically, this session aims to:

• Clarify how Medicare and commercial payers define an overpayment
• Explain when an overpayment is considered “identified” and when refund timelines are triggered
• Review Medicare’s 60‑day overpayment rule and its enforcement implications
• Contrast Medicare requirements with commercial payer refund policies and contractual obligations
• Identify common audit findings and billing errors that lead to overpayments
• Provide guidance on documentation, audit response, and refund submission expectations
• Support attendees in developing or refining internal overpayment tracking and refund workflows

The session is structured to help organizations move beyond reactive refund practices and toward proactive compliance strategies that align with payer requirements, reduce audit exposure, and mitigate regulatory and financial risk.

Webinar Agenda

• Overview of Overpayments
• Medicare 60-Day Rule
• Commercial Payer Policies
• Audit Triggers
• Refund Best Practices

Webinar Highlights

• Medicare vs commercial overpayment rules
• Refund timelines
• Audit-driven vs self-identified overpayments
• Compliance risk reduction strategies

Who Should Attend

Coding Managers, Coding Auditors, Revenue Integrity Professionals, Compliance Officers, Billing Managers, Practice Administrators, HIM Professionals, CDI Specialists.