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17 February
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Patient Overpayments in Florida: Why Sitting on Credits Is No Longer an Option

Posted by Jamaal R. Jones, Esq.
in Blog

By: Nailah Morris

It starts with a number that looks too small to matter.

A patient pays at check-in. The claim goes out. Two weeks later, the insurer processes the EOB. Your system posts the payment. And now the account shows a credit balance: $18.42. Nobody panics. Nobody calls compliance. Nobody rushes to refund $18.42. It just sits there. Because in most organizations, patient credits live in the same place as “we will get to it after month-end” and “the vendor is working the queue.” They are treated like a back-office nuisance, not a regulatory risk.

Florida just changed that.

Effective January 1, 2026, Florida law (CS/CS/SB 1808) makes one thing painfully clear: sitting on patient overpayments is no longer an option. Once an overpayment is determined, you have 30 days to refund it, whether the delay is intentional, accidental, or caused by someone you hired. The simple truth: a credit balance is not neutral. It is a clock.

What the New Law Requires (In Plain Terms)

If you are licensed in Florida under:

  • Chapter 456, Florida Statutes (Department of Health regulated practitioners), or
  • Chapter 408 (AHCA-licensed providers),

The rule is straightforward:

  • Determine whether an overpayment occurred.
  • Refund it within 30 days of that determination.

Here is where most compliance problems will be born:

  • The trigger is not when the overpayment happened.
  • The trigger is when you knew or should have known it existed.

That “should have known” language is where the risk lives, because regulators do not audit feelings. They audit systems, timestamps, reports, and notes. If your records show the credit was visible, the question becomes simple: why did it sit?

Who Is Covered (and Who Is Not)

This statute is narrow, but it targets a very common situation.

Covered: the “patient paid up front, insurer paid later” scenario

The 30-day refund requirement applies when:

  • A patient overpaid for services, and
  • The provider submitted a claim for those services to:
    • a private insurer or HMO, or
    • a government program (Medicare, Medicaid, TRICARE, etc.)

Think about the everyday workflow:

  • Patient pays a copay, deductible, or coinsurance at the front desk.
  • Insurance processes the claim later.
  • The final payment reveals the patient paid too much.
  • A credit balance appears.

That is the scenario Florida is addressing.

Not covered: self-pay and insurer overpayments

The law does not apply to:

  • Self-pay/cash-pay patients.
  • Services not billed to an insurer or government program.
  • Overpayments made by insurers (those are governed by existing insurance statutes).

So this is not “every credit balance everywhere.” It is a targeted rule aimed at insured/government-billed claims where patient money is involved.

Enforcement Risk: Florida Added Teeth

Refunds are not new. What is new is the state’s willingness to treat delay as a compliance failure, not a clerical inconvenience.

If you are AHCA-licensed:

AHCA may impose administrative fines up to $500 per violation. And under existing enforcement concepts, each day the refund remains unpaid can be treated as a separate violation. That is how small credits become big problems: not because the amount is large, but because the days stack.

If you are DOH-licensed:

For physicians and other DOH-regulated professionals, failure to refund in a timely manner is grounds for discipline, including:

  • Fines.
  • Probation or restrictions.
  • In serious cases, suspension or revocation of licensure.

The uncomfortable part: even if billing is outsourced, the license is not. Simple truth: you can delegate the work, but you cannot delegate the accountability.

The Gray Area That Will Get People Hurt: When Is an Overpayment “Determined”?

The statute does not define determination with a neat, compliance-friendly timestamp. That ambiguity is not a loophole. It is a trap. In the real world, “determination” will be inferred from evidence such as:

  • Account reconciliation dates.
  • Payment posting entries.
  • System-generated alerts or credit balance reports.
  • Internal compliance reviews.
  • Documentation created by third-party billing vendors.

Here is how this goes sideways in practice:

Scenario 1 | The report exists, but nobody owns it: Your system generates a weekly credit balance report. It lands in a folder. No one reviews it for two weeks. The credits are “there,” but not “worked.” Regulators will not care that it was inconvenient. They will care that it was visible.

Scenario 2 | The EOB posts, and the clock starts quietly: Payment posting happens on Tuesday. Credit appears on Wednesday. Your team “determines” overpayments during the month-end close. Regulators may argue your system determined it the moment the credit was posted or flagged.

Scenario 3 | The vendor knew first: Your billing company flags the credit, adds a note, and puts it in a queue. You do not see it until later. The record still exists. And the license still has your name on it. Providers should assume regulators will look at records, timestamps, and system notes, not intent. If a system flags a credit balance and nothing happens, that record may become the start of the 30-day clock.

This is especially important if you use:

  • Third-party billing companies
  • Centralized revenue cycle platforms
  • Automated posting systems

Automation is not protection. It is documentation.

Why Management Companies and Billing Entities Matter More Than Ever

The statute expressly extends the refund obligation to billing departments, management companies, and group practices that accept patient payments on behalf of licensed providers. That sounds operational. It is actually governance. Because many providers are employed by or contract with large entities where they do not control refund workflows day-to-day. Yet the treating provider remains exposed.

Expect regulators to test one question:

“How do you supervise and monitor the people handling patient money under your license?”

If the answer is “I assumed the vendor handled it,” you are not describing a control. You are describing a hope.

Practical Compliance Takeaways (What to Do This Week, Not “Someday”)

This law is less about refunds and more about process discipline. If you want to reduce risk, stop treating credits as accounting leftovers and start treating them like regulated events. Here is a practical starting list:

  1. Define “determination” internally—on purpose: Pick a clear operational trigger (e.g., posting date, credit report generation date, reconciliation completion date) and document it. Ambiguity is where enforcement grows.
  2. Create a credit-balance workflow with owners and timestamps: Every credit should move through a queue: identified → validated → approved → refunded → documented.
  3. Build a 30-day tracker that cannot be ignored: If you cannot see aging, you cannot manage risk. Track credit date, “determination” date, refund due date, and completion date.
  4. Update vendor agreements to match the law: Add timeliness obligations, documentation requirements, escalation rules, and audit rights. Vendor delay should be a contract problem, not your compliance problem.
  5. Train billing staff on escalation and documentation: If a refund is delayed, the file should show why, who approved the delay, and what steps were taken. Silence reads like neglect.
  6. Update patient financial policies and scripts: Your written policies should reflect refund timelines so front desk, billing, and leadership all communicate the same expectation.

Being “too busy” or “waiting for the system to catch up” will not be a defense. It will be a record.

The Bottom Line

Florida closed a long-standing gap in patient financial protections. Beginning January 1, 2026, patient overpayments are no longer passive credits. They are time-sensitive compliance obligations. Providers who treat refunds as an afterthought risk fines, disciplinary scrutiny, and reputational harm. Providers who tighten their processes now will not only reduce regulatory exposure, they will also demonstrate transparency and accountability to patients in an era where both matter more than ever.

Simple truth to end where we started: the credit balance is not “extra work.” It is a compliance clock you can either manage or explain later.

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It should be noted that I am not your lawyer (unless you have presently retained my services through a retainer agreement). This post is not intended as legal advice; it is purely educational and informational, and no attorney-client relationship shall result after reading it. Please consult your own attorney for legal advice. If you do not have one and would like to retain my legal services, please get in touch with me using the contact information listed above.

All information and references to laws, rules, regulations, and advisory opinions were accurate as of this time, but laws are constantly evolving. Please get in touch with me to ensure that the law governing your business is up to date. Thank you.

19 March
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What are Work Relative Value Units (wRVUs) in Physician Employment Agreements?

Posted by Jamaal R. Jones, Esq.
in Blog

By: Ashley Lockett

When a physician provides a service, the reimbursement amount for that work is often measured through a metric referred to as work relative value units (wRVU). Although not every physician may be subject to wRVUs, such as physicians who have their own private practice, many physicians who work in large healthcare organizations may be required to meet a minimum amount of wRVUs.

The goal of the wRVU model is for physicians’ compensation to be directly correlated to the amount of work they perform, regardless of the patient’s insurance plan or the revenue generated during the services. Focusing on the amount of work performed has proven to be more effective than the previous method of tracking a physician’s productivity by the number of patients seen and number of services performed. Additionally, calculating reimbursement simply off the amount charged to the patient can be ineffective as well because the amount does not necessarily reflect the underlying value of the work provided. As such, the current wRVU model is the standard compensation model that many physicians and employers use in the healthcare industry.

How wRVUs Operate

The calculation of wRVUs considers a multitude of factors such as:

  • the work the physician is performing;
  • the costs associated with the necessary equipment;
  • the skill required;
  • the costs of liability insurance and;
  • the time associated with the procedure.

The total work that is involved in a physician performing a service typically includes the preservice work provided before the service (i.e., reviewing medical records, surgery prep), the work provided during the service (i.e., medical examination, surgery), and the work provided after the service has been performed (i.e., post-operative care, further documentation).

Typically, each service performed by a physician has an associated number called a CPT code. Each CPT code receives a wRVU that is combined with the previously mentioned factors to create a total RVU. From there, the total RVU is multiplied by the Medicare conversion factor (currently placed at $32.74 in 2024) to determine the reimbursement amount of the service. The Medicare conversation rate is determined by the Medicare Economic Index, however, it is important to note that private insurance companies and Medicaid may have a different conversion rate for wRVU to dollars.

Benefits of the wRVU Model

One of the most common benefits of the wRVU model is the transparency associated with it. The wRVU’s and the conversion factor are standard. This makes it easier for a hospital to administer and prevents one doctor from getting paid more than another while performing the same work. Despite wRVUs leveling the playing field by standardizing the compensation for each service performed, the implementation of wRVUs can create healthy competition among physicians as well. The wRVU system encourages physicians to maintain a steady stream of patients. As a result, the hospital has the possibility to flourish as physicians compete to acquire new patients.

The steady stream of patients not only helps the hospital in acquiring new patients but also in retaining already existing patients. The wRVU model may encourage physicians to follow up with their patients more often, as post-operative care and other post-procedure services are included in the compensation model.

Downsides to be Aware of

Though the wRVU can provide many benefits to employers such as easy implementation of the system and healthy competition in the work environment which increases physician productivity and patient numbers, the wRVU model can also have some cons.

Since the wRVU model relies on CPT codes in their final calculations for reimbursement, services performed by physicians that do not have an associated CPT code, such as tasks performed outside of patient care do not get compensated. In an effort to reach the amount of wRVU’s physicians need, those tasks not associated with a CPT code may lose priority to tasks that will be compensated instead. This can also encourage physicians to focus on the quantity of the work they perform, rather than the quality.

While healthy competition in a work environment can be a good thing, especially for employers, for physicians it may create a challenging work environment. In a hospital, peers often collaborate to discuss the best route for a patient’s treatment. In a competitive environment, it may discourage that collaboration, harming not only the physician’s productivity but the patient as well.

As a result of these effects the wRVU model may have on physicians, it can lead to burnout which then can impact the physician, patient, and the employer.

Negotiating wRVUs

Some physicians may have the ability to negotiate their wRVUs. The process for negotiations may be more limited for physicians in larger organizations but may be possible for those in private practices or smaller groups. Understanding the terms of the contract can help a physician negotiate wRVUs with insurance companies or a hospital administration. It is important to note, however, that reimbursement rates provided by Medicare and Medicaid are determined by the government and not open for negotiation.

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It should be noted that I am not your lawyer (unless you have presently retained my services through a retainer agreement). This post is not intended as legal advice, it is purely educational and informational, and no attorney-client relationship shall result after reading it. Please consult your own attorney for legal advice. If you do not have one and would like to retain my legal services, please contact me using the contact information listed above.

All information and references made to laws, rules, regulations, and advisory opinions were accurate based on the law as it existed at this time, but laws are constantly evolving. Please contact me to be sure that the law which will govern your business is current. Thank you.

17 June
0 Comments
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Can I Continue to Run a Medical Practice After the Sole Physician’s Death?

Posted by Jamaal R. Jones, Esq.
in Blog
Authored by Marcus Leonard and Jamaal R. Jones, Esq.

Authored by Marcus Leonard and Jamaal R. Jones, Esq.

Inevitably, we will all pass away at some point in hopefully the distant future. Some of our deaths will be expected while others will come as a complete shock. Many people formulate a plan for after their passing and make arrangements accordingly for the succession of their personal and business affairs and belongings, while others do not. Occasionally, that deceased person happens to be the only physician in the medical practice. The staff and surviving family members have to quickly determine what their options are and whether they can legally continue to operate the practice without the physician.

Florida does not have the same Corporate Practice of Medicine Prohibitions as other states. In short, this means that you do not have to be a licensed medical doctor or doctor of osteopathy to own a medical practice. Many people erroneously believe that because of this fact they can continue to run the physician’s practice without taking any further action after she passes away. The Florida Health Care Clinic Act (the “Act”) requires that all health care clinics operating in Florida maintain a valid license by the State unless they fall within a statutory exemption. Also, if the health care clinic is cash-pay only and not accepting reimbursement from a commercial payor, Medicare or Medicaid then Florida law allows the business to continue to run without first obtaining the license. According to the Act, a “clinic” is defined as an entity which provides health care services to patients and bills third party payers for reimbursement for providing those health care services. Clinics that are “wholly owned by one or more licensed health care practitioners” are exempt from obtaining a health care clinic license. Thus, if a clinic is owned by a licensed health care practitioner who is supervising the services performed at the clinic and who is legally responsible for the entity’s compliance with all federal and state laws, the clinic falls within one of the exceptions and is exempt from the Act’s licensure requirements. However, in the untimely event that a sole physician/owner passes away, the clinic is no longer afforded exemption from the Act’s licensing requirements and is no longer in compliance with the law.

 

What are my Options?

In this instance, the family members have the following choices: (1) close the practice; (2) sell the practice; or (3) apply for a health care clinic license. If the decision is made to close the practice then you have to make sure that you wind up and dissolve the business accordingly. Alternatively, it can be tricky if the decision is made to sell the practice. Even if you hire another physician to provide treatment to the patients while you try to find a buyer for the practice you will still be violating the Act. As a result, you must not continue to provide health care services until the practice is sold to someone or an entity that qualifies for an exemption under the Act or until you receive a health care clinic license.

This is important because Florida law provides that an insurer is not required to pay for medical treatment that is not lawfully provided. The plain language of the Act makes clear that a claim for reimbursement made by a clinic that is not properly licensed or that is otherwise operating in violation of the Act, constitutes an unlawful charge that is deemed non-compensable and unenforceable.

Filing the application with the Agency for Health Care Administration for a health care clinic license it tedious and must be done carefully or you risk denial. Also, the applicant should not expect to receive the license expeditiously.

 

Penalties

Under the Act, it is considered theft for an entity that does not have a health care clinic license and does not meet the requirements for an exemption to submit a charge for reimbursement. You can be charged with committing a third-degree felony if you operate an unlicensed clinic. Each day that the person violates the act is considered a separate offense. If a physician who is working for a clinic knows or has reasonable cause that the clinic is operating without a license and fails to report the clinic then that physician will be reported to the medical board for failure to report the clinic. There will also be administrative penalties imposed upon those who practice without a license.

 

Conclusion

A clinic is required to register for a license under the Act even if they were previously exempt from licensure requirements prior to the physician’s death unless some other applicable exemption exists. A sole health care provider should create a plan for succession in the event of their death. For example, upon the physician’s death the shares of the practice can “automatically” transfer to another physician of their choosing so that there isn’t a gap in care to patients. This would require careful planning and legal considerations beforehand. Our firm is well equipped with knowledgeable and experienced health law attorneys who can assist you with planning for this difficult event.

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It should be noted that I am not your lawyer (unless you have presently retained my services through a retainer agreement). This post is not intended as legal advice, it is purely educational and informational, and no attorney-client relationship shall result after reading it. Please consult your own attorney for legal advice. If you do not have one and would like to retain my legal services, please contact me using the contact information listed above.

 

All information and references made to laws, rules, regulations, and advisory opinions were accurate based on the law as it existed at this time, but laws are constantly evolving. Please contact me to be sure that the law which will govern your business is current. Thank you.

17 April
63 Comments
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Establishing A Mobile IV Therapy Clinic in Florida

Posted by Jamaal R. Jones, Esq.
in Blog

Recently, I’ve received several inquiries from doctors, nurses and healthcare entrepreneurs who are considering opening mobile intravenous therapy clinics throughout Florida but have some legal concerns. In the past, there weren’t many Florida laws enacted to significantly regulate IV therapy clinics whether mobile or not and not much has changed over the years. Florida doesn’t have corporate practice of medicine limitations which is attractive for many of these individuals.

What is Intravenous Therapy?

The administration of intravenous (“IV”) therapy is defined as the therapeutic infusion and/or injection of substances (i.e. supplements, vitamins and minerals) through the venous peripheral system, consisting of activity which includes observing, initiating, monitoring, discontinuing, maintaining, regulating, adjusting, documenting, planning, interviewing and evaluating. It involves the administration of medication through a needle or catheter. It is believed by some that delivering medication directly into the bloodstream can help to quickly manage a patient’s pain or symptoms. In addition to treating illnesses, IV therapy proponents claim that it may also increase athletic performance, reduce jet lag, build immunity or help with dehydration by using vitamins and minerals. According to several practitioners, IV therapy should be customized for each patient’s needs to maximize results.

What is a Mobile IV Therapy Clinic?

A license issued by the Agency for Healthcare Administration (“Agency”) is required to operate a clinic in Florida. Each clinic location must be licensed separately regardless of whether the clinic is operated under the same business name or management as another clinic. In Florida, a clinic is an entity where health care services are provided to individuals and which tenders charges for reimbursement for those services, including a mobile clinic and a portable equipment provider. A mobile clinic means a movable or detached self-contained health care unit within or from which direct health care services are provided to individuals. Each mobile clinic must obtain a separate healthcare clinic license and must provide to the Agency, at least quarterly, its projected street location to enable the agency to locate and inspect the clinic.

Additionally, a home infusion therapy provider must be licensed as a home health agency or nurse registry. Nurse registries can refer nurses to patients to provide home infusion therapy. “Home infusion therapy provider” means an organization that employs, contracts with, or refers a licensed professional who has received advanced training and experience in intravenous infusion therapy and who administers infusion therapy to a patient in the patient’s home or place of residence. “Home infusion therapy” means the administration of intravenous pharmacological or nutritional products to a patient in his or her home.

A healthcare professional licensed as an acupuncturist, medical doctor, osteopathic doctor, nurse, midwife, speech pathologist, occupational therapist, physical therapist and others, whether or not incorporated, are exempt from the licensure requirements of Florida Statute 400.464 if they are acting alone within the scope of his or her professional license to provide care to patients in their homes.

The application for a healthcare clinic license must include information pertaining to the name, residence and business address, phone number, social security number and license number of the medical or clinic director of the licensed medical providers employed or under contract with the clinic.

Who Can Provide IV Therapy?

Most Florida licensed medical doctors, osteopathic doctors, dentists, registered nurses, medical assistants, and licensed practical nurses may provide iv therapy to patients if they possess the appropriate certifications and training. Several of these practitioners must complete a required 30-hour IV certification course. Regardless of who you hire to provide IV therapy they should have several years of experience with administering IVs.

1. Emergency Medical Technicians and Paramedics

Some have inquired about the appropriateness of hiring an emergency medical technician (“EMT”) or a paramedic to administer IV therapy to the clinic’s patients. Florida law makes a clear distinction between what types of services an EMT and paramedic may provide. An EMT is defined as a person who is certified by the Department of Health to perform “basic life support”. A paramedic is defined as someone who is certified by the DOH to provide basic and advanced life support. Paramedics hold a certificate of successful completion in “advanced cardiac life support” from the American Heart Association (“AHA”) or its equivalent, whereas EMTs are only required to hold a current AHA cardiopulmonary resuscitation course card. This distinction between basic and advanced life support is important. Florida law states that Advanced life support means assessment or treatment by an appropriately qualified individual to use techniques such as endotracheal intubation, the administration of drugs or intravenous fluids, cardiac monitoring and cardiac defibrillation. Basic life support means the assessment or treatment by a person qualified to use techniques as described in the EMT-Basic National Standard Curriculum or the National EMS Education Standards of the USDOT, which includes the administration of oxygen and other techniques. The DOH has taken action against several IV clinics, which were identified as posing a potential health threat to Florida’s residents and visitors. DOH investigators have issued several cease and desist notices to paramedics and EMTs for operating outside their scope of practice for practicing medicine without the proper license.

2. Medical Assistants

Medical Assistants involved in the performance of IV therapy must receive training and certification in IV procedures. All IV therapy provided by a medical assistant must be done under direct supervision of a practitioner who is trained and has experience in the administration, potential side effect and complications related to IV therapy. If services are provided in an office setting (or mobile clinic) the experienced practitioner should always present in the office whenever a medical assistant is providing IV therapy to a patient. In a Florida Board of Medicine case, the Board held that medical assistants may lawfully perform IV infusion therapy as long as it is performed under the direct supervision and responsibility of a Florida licensed physician that is always present in the office whenever a medical assistant is providing the therapy to a patient.

3. Licensed Practical Nurses

Aspects of IV therapy may be outside the scope of practice of a licensed practical nurse (“LPN”) unless under the direct supervision of the registered professional nurse or physician and which shall not be performed or initiated by the LPN without direct supervision include the following:

          • Initiation of blood and blood products;
          • Initiation or administration of cancer chemotherapy;
          • Initiation of plasma expanders;
          • Initiation or administration of investigational drugs;
          • Mixing IV solution;
          • IV pushes, except heparin flushes and saline flushes.

With the exception of those aspects of IV therapy deemed outside the scope of practice of the LPN, and subject to the approval of the institution at which the LPN is employed, any LPN who meets the competency knowledge requirements is authorized to administer intravenous therapy under the direction of a registered professional nurse. “Under the direction of a registered professional nurse” means that the registered professional nurse has delegated IV therapy functions to a qualified LPN. The registered professional nurse does not in all instances have to be on the premises in order for the licensed practical nurse to perform the delegated functions. Direct supervision means on the premises and immediately physically available. Only license practical nurses that have met the education and competency requirement in state nursing rules can provide infusion therapy.

Who Pays for IV Therapy?

The overwhelming majority of mobile IV therapy patients will be self-pay. Medicare, Medicaid and commercial payors typically won’t cover the costs for these treatments. However, I have seen reports where commercial payors may utilize specific per diem codes to pay certain infusion providers for services, supplies and equipment. Medicare has limited coverage for home infused drugs under the Part B and Part D benefit when it is medically justified.

Other Considerations

As a medical provider you must anticipate that medical emergencies may emerge even during the most routine situations. Providers should have adequate insurance coverage for claims arising out of injury to or death of a patient and damage to the property of others resulting from any cause for which the owner of the mobile IV clinic would be liable. In lieu of malpractice insurance, a provider may furnish a certificate of self-insurance as evidence that the provider has established adequate self-insurance to cover these types of risks.

Because IV injection involves direct access into the patient’s circulatory system, sterile equipment and sterile technique must be used to avoid the introduction of any pathogens into a patient’s bloodstream. The practitioner must inspect vials for signs of contamination such as particulate matter, cloudiness, or inappropriate color. The practitioner must use a sterile alcohol wipe to cleanse the top of the vial and withdraw the fluid form the vial using a sterile needle and a sterile syringe. Practitioners must follow Universal Precautions, as described by the Occupational Safety and Health Standards (“OSHA”). To ensure safe and proper administration of infusion drugs you should consider providing some of the following services:

      • Patient Assessment
      • Drug interaction monitoring
      • Patient education
      • Patient monitoring
      • Car planning
      • Maintenance of storage, preparation, dispensing and quality control of all infusion medications and equipment.

I would advise against treating individuals under the influence of alcohol, suffering from congestive heart failure, history of aneurysms, kidney or renal disease and high blood pressure. Patients should also be 18 or older and valid written consent forms should be signed by every patient.

You must have a medical director who is employed or contracted by the clinic licensee and who provides medical supervision, including appropriate quality assurance but not including administrative and managerial functions, for daily operations and training. Additionally, a health care practitioner may not serve as the clinic director if the services provided at the clinic are beyond the scope of that practitioner’s license.

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It should be noted that I am not your lawyer (unless you have presently retained my services through a retainer agreement). This post is not intended as legal advice, it is purely educational and informational, and no attorney-client relationship shall result after reading it. Please consult your own attorney for legal advice. If you do not have one and would like to retain my legal services, please contact me using the contact information listed above.

All information and references made to laws, rules, regulations, and advisory opinions were accurate based on the law as it existed at this time, but laws are constantly evolving. Please contact me to be sure that the law which will govern your business is current. Thank you.

IV Hydration Masterclass: Legal Requirements of Starting an IV Hydration Business