Under circumstances where the NCCI manual instructs that a Column 1 code is not reportable with a Column 2 code, what risk occurs if both services are paid?

Under circumstances where the NCCI manual instructs that a Column 1 code is not reportable with a Column 2 code, what risk occurs if both services are paid?

• A. It results in an audit hold.
• B. It triggers automatic repayment in full.
• C. It creates no risk.
• D. It involves reverse FCA liability and must disclose/refund overpayment.

Answer: (D)

When NCCI marks a Column 1 code as not reportable with a Column 2 code, those two codes are mutually exclusive for payment on the same claim. If both services are paid, an overpayment has occurred. The main risk here is reverse False Claims Act liability: the entity that received the funds can be liable for having kept an overpayment. The correct action is to disclose the overpayment and refund the amount (or otherwise correct the payment) to avoid penalties. This remedy is central because it directly addresses the overpayment and the potential liability tied to retaining government funds.

When NCCI marks a Column 1 code as not reportable with a Column 2 code, those two codes are mutually exclusive for payment on the same claim. If both services are paid, an overpayment has occurred. The main risk here is reverse False Claims Act liability: the entity that received the funds can be liable for having kept an overpayment. The correct action is to disclose the overpayment and refund the amount (or otherwise correct the payment) to avoid penalties. This remedy is central because it directly addresses the overpayment and the potential liability tied to retaining government funds.