Guidance Issued on Reporting Health Care Worker Bonus Overpayments

With the claim submission period for vesting period 3 about to begin on April 1^st, the Department of Health (DOH) has posted a new Frequently Asked Question (FAQ) on the Health Care Worker Bonus (HWB) program webpage addressing what employers should do if they identify an overpayment. Please note that the information applies solely to overpayments – it does not address underpayment issues or other corrections.

Those identifying an overpayment are required to report, return, and explain it to the Office of the Medicaid Inspector General (OMIG) using a self-disclosure process specifically designed for bonus overpayments. As outlined on the dedicated webpage here, those reporting an overpayment need to complete an HWB Self-Disclosure Submission Statement and Certification Statement and submit those along with an Overpayment Report Excel spreadsheet and other required materials through OMIG’s secure uplink.

Once that is submitted, OMIG’s Self-Disclosure Unit will contact the provider with a project number for reference and a request for any additional information required to process the disclosure. At the conclusion of its review, OMIG will issue a Final Letter, which will include instructions on repayment. Please keep in mind that employers are not allowed to recover any bonus payment made to an employee, even if that payment is subsequently identified as an overpayment.

The HWB program website is here, with the new FAQ copied below. 

Q. What happens if I identify an overpayment after a submission period is closed?

A. Please note this process is for EMPLOYERS only. Employers are required to report, return, and explain any overpaid HWB funds received. Additional information, including directions on reporting and returning your overpayment can be found here: Office of the Medicaid Inspector General - Self Disclosure of HWB Program Payments. Please Note: Employers are prohibited from recovering bonuses paid to Employees under the HWB program even if the payment is later identified as an overpayment. See “Q. Can an Employer take back the HWB bonus from and Employee?”.