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Attention Florida Healthcare Providers:
A new Florida law, CS/CS/SB 1808, concerning the refund of overpayments by patients to healthcare providers, will take effect on January 1, 2026.
This law requires licensed health care facilities and practitioners to refund any patient overpayment within 30 days of determining that the overpayment was made. Failure to comply may result in disciplinary action for medical and dental providers and, if AHCA-licensed, a $500 fine per violation.
Key Provisions of the Law
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Refunds: Licensed healthcare providers must refund patient overpayments within 30 days of identifying the overpayment.
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Applicability: Applies to overpayments received when a provider has filed a reimbursement claim with a government-sponsored program or private insurer.
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Exceptions: Does not apply to overpayments made by uninsured, self-pay, or cash-pay patients.
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Disciplinary Actions: Failure to comply with refund requirements may lead to disciplinary action against the healthcare practitioner. If ACHA-licensed, providers may be assessed a $500 fine for each violation.
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Effective Date: January 1, 2026
Our Recommendation
We strongly recommend that all healthcare providers and facilities review their Revenue Cycle Management (RCM) processes to ensure:
- Systems are in place to identify and process patient overpayments within 30 days of identification.
- Standard Operating Procedures (SOPs) are documented to comply with this new state requirement.
Stay compliant and proactive, review your processes now to avoid penalties and ensure a smooth transition before the law takes effect.
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