As with prepayment review actions, a suspension action can adversely impact a billing company if this contingency is not addressed in its billing agreement.
Keep in mind, when a provider is placed on suspension by Medicare:
The suspended provider can continue to see and treat Medicare beneficiaries.
The suspended provider can continue to bill for services rendered.
Nevertheless, any monies that may be due to a provider while they are suspended are essentially placed into a suspense account. These funds are not distributed to the provider.
Instead, a post payment audit is later conducted by a ZPIC and once an alleged over payment is identified the monies being held in suspense are applied to the alleged overpayment. A provider then has to seek payment through the administrative appeals process.