With complex filing requirements in all 50 states, unclaimed property can become complicated fast. Crowe can make unclaimed property compliance easy for you. By using your healthcare organization’s data, we’re able to help you achieve compliance, limit audit exposure, and resolve large credit balances that accrue due to overpayment.
Healthcare unclaimed property specialists
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Unclaimed property laws have become a powerful revenue-generating tool for states. That means there’s every incentive for states to target entities suspected of noncompliance – but many healthcare organizations are not ready.
We often hear, “I’m in compliance.” But we’ve seen a lot of uncovered risks in healthcare unclaimed property.
One big gap? Requirements for compliance in all the jurisdictions you’re registered in, not just where you’re headquartered.
With one of the largest unclaimed property teams in the country, we understand the unclaimed property laws in all 54 jurisdictions. We can tell you where you need to be compliant – and then help you make it happen.
Unclaimed property is any unresolved liability or obligation to another person or entity. Examples of unclaimed property in healthcare include uncashed checks (payroll refund and accounts payable checks), aged credits, unposted/unapplied cash, and patient refunds.
All states require you to turn unclaimed property over to the state after a certain holding or dormancy period. Organizations cannot keep this money.
If unclaimed property compliance isn’t handled appropriately, the consequences can be very painful. Unclaimed property audits have the potential to be extremely costly to healthcare organizations, with extensive resource investment and potential fines and penalties.
Properly managing healthcare unclaimed property can help protect your organization’s brand and reputation. Your organization doesn’t want to be known for keeping money from its patients.
It’s important to note that the healthcare industry has been identified by states for audits of unclaimed property compliance due to the complex payment processes that prevail in healthcare. Consolidation between healthcare organizations creates additional exposure.
Almost all companies, big and small, have unclaimed property, and healthcare unclaimed property takes many shapes and sizes.
It’s possible that historically your organization has written off aged credits and voided unclaimed checks, but this practice does not align with unclaimed property compliance. Even if your organization doesn’t have any healthcare unclaimed property, some states still require negative or zero-dollar reporting to demonstrate that you have knowledge of unclaimed property reporting requirements and that you are complying.
Unfortunately, that might not be the case. Healthcare organizations are subject to unclaimed property laws in many jurisdictions, including states where you don’t even have facilities.
Because healthcare unclaimed property is reported to the owner states, organizations also are liable for unclaimed property compliance in states where vendors, patients, and payors are located. These unclaimed property reporting requirements can add up fast.
For example, a business traveler from California receives healthcare treatment in Illinois. If the patient goes home and does not claim a refund, the Illinois hospital will have to complete a California unclaimed property filing, too.
In the same way, when a health system is located in California and an insurance payor is located in Delaware, the California health system will have to complete Delaware unclaimed property filings as well.
Unfortunately, no. All states have different unclaimed property reporting requirements, dormancy requirements, and deadlines.
Because most companies need to complete unclaimed property filings in multiple states, even though they're not located there, unclaimed property compliance can be extremely complex. This is why it can be valuable to consult with an unclaimed property compliance specialist that has deep knowledge of various states’ unclaimed property reporting requirements.
Most states require unclaimed property reporting all the way down to the penny level. In healthcare, it’s very common to have a small dollar write-off policy. Write-offs are permitted if they get written off into unclaimed property, but not into income.
It’s important to understand that write-offs in general are an area that unclaimed property auditors acutely focus on. Unclaimed property specialists can be a valuable aid in identifying hot-button unclaimed property audit areas such as this.
There are a lot of unclaimed property letters being sent by states these days. Some are as innocent as reminders to file, but most are attempting to evaluate your unclaimed property to see if you’re a good candidate for an unclaimed property audit.
That’s why you should be very judicious in how you respond to various questions on that unclaimed property letter.
In the worst-case scenario, you have received a letter indicating you have already been tagged for an unclaimed property audit. Unclaimed property audits, often performed by a contingency fee examiner, require significant prep internally and can last from 3 to 7 years. In these cases, it’s a good idea to consult with an unclaimed property compliance specialist.
Compliance usually costs less than penalties. With some attention now, you can prevent unclaimed property from claiming lots of resources later.
Let’s start with a brief chat.
We’ll give you a road map to compliance.
Avoid penalties – and start realizing a financial return.
Crowe Credit Income Recovery
Using machine learning, we’re able to deliver high-confidence predictions on credits, with fewer touches from your team.
Crowe Automated Reconciliation
Avoid the write-offs that come with unapplied cash. Our automated reconciliation solution provides a three-way match between the bank, your patient accounting systems, and your general ledger.
Crowe Account Resolution AI
Create sound, sustainable documentation, charge capture, and coding practices that can lead to more revenue for your organization.
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1 Internal Source System, October 2022
2 Internal Source System, October 2022
3 Definitive Healthcare and CRM, October 2022