Fiscal Note
Fiscal Services Division
HF 2268 – Medicaid, Refunds and Offsets (LSB5556HV)
Staff Contact: Eric Richardson (515.281.6767) eric.richardson@legis.iowa.gov
Fiscal Note Version – New
Description
House File 2268 limits any post-payment review of claims paid under either Medicaid fee-for-
service (FFS) or managed care administration to 24 months from the date of payment unless
the claim involves fraud or misrepresentation. In addition, any provider overpayment identified
for which 24 months or more have elapsed since the date of payment of the claim shall not be
subject to repayment or to offset against future reimbursement of claims by the provider, and
any improper payment identified through a review may be resubmitted by the provider as a
claims adjustment. The Bill does not apply to retroactive Medicaid cost settlements or rate
changes based on a Medicaid or Medicare cost report.
The Bill takes effect upon enactment.
Background
Iowa Code section 249A.42 allows an administrative action to recover a provider overpayment
within a period of five years from the date an overpayment was incurred, which would be
changed in the Bill to 24 months for instances of overpayment that do not involve fraud or
misrepresentation.
Assumptions
• The Department of Health and Human Services (HHS) will be required to return the federal
share of overpayments to the federal government regardless of collection of overpayments
from providers.
• Managed care organizations (MCOs) will make administrative efforts for any recoveries
within the 24-month window in the Bill, if enacted, and the Bill will not cause an increase in
capitation rate payments to the MCOs.
• Post-payment review does not apply to retroactive Medicaid cost settlements or rate
changes based on a Medicaid or Medicare cost report.
• According to the HHS, the fiscal impact will fall solely upon State Medicaid’s FFS program at
a cost of approximately $535,000 annually.
• The Bill takes effect upon enactment; however, the impact to the HHS is estimated to begin
in FY 2025.
• The State fiscal impact will include increased costs to the General Fund Medical Assistance
(Medicaid) appropriation.
Fiscal Impact
House File 2268 is estimated to increase costs to the State Medicaid program by approximately
$535,000 annually due to lost recoveries, beginning in FY 2025.
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Source
Department of Health and Human Services
/s/ Jennifer Acton
February 20, 2024
Doc ID 1447008
The fiscal note for this Bill was prepared pursuant to Joint Rule 17 and the Iowa Code. Data used in developing this
fiscal note is available from the Fiscal Services Division of the Legislative Services Agency upon request.
www.legis.iowa.gov
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