2024-ERAG-002 - Recommendation 3

We recommend that the contracting officer require the Association to provide evidence or documentation demonstrating that the Plan has implemented the necessary corrective actions to ensure that claim overpayments are adequately pursued, monitored, recovered, and returned to the FEHBP, as required by Section 2.3(g) of Contract CS 1039. If the options are available and cost effective, the Plan should use provider offsets, future FEP member benefit payment offsets, and/or third-party collections to recover claim overpayments. The Plan should also avoid negotiating provider agreements with claim overpayment recovery exclusions that adversely effect the FEHBP and contradict Section 2.3(g) of the FEHBP contract, such as excluding the use of provider offsets and/or third-party collections to recover overpayments. The contracting officer should also require the Association to provide a certification that the Plan has implemented these corrective actions.