Healthcare Industry Insights into Unclaimed Property

Paola Narez
April 21, 2021

Historically, the healthcare industry has experienced challenges in identifying and reporting unclaimed property. This is due to several reasons including a lack of clear statutory guidance, limited understanding of the potential unclaimed property liabilities which they are truly subject, and conflicting laws (i.e., refund recoupment, prompt payment, HIPAA, etc.). 

The fundamental understanding that healthcare entities need to be aware of, as well as all other organizations subject to unclaimed property laws, is that property held for longer than the allowed dormancy period is therefore deemed abandoned by the owner. To be compliant, the entity in possession of the unclaimed property must perform the statutory due diligence to reunite the property with the rightful owner. If unsuccessful, the entity must remit and report the unclaimed property to the corresponding state. This process becomes more challenging when involving multiple parties for the payment for services; it requires more effort to identify the rightful owner of the credit and validate it as unclaimed property. 

Potential sources of unclaimed property in healthcare may include write off accounts with credit balances, unapplied cash, patient credit balances, uncashed payroll or vendor checks, overpayments, and unidentified remittances. Accounts receivables are particularly susceptible to generating unclaimed property within this industry. As part of normal business operations, significant patient credit balances occur from transactions unique to the industry, such as insurance company overpayments, billing system updates, payments of the same bill by multiple sources, payments that aren’t matched to a specific patient or treatment, and the reimbursement processes.  The aforementioned issues, in concert with record retention limitations, creates difficulty in proving proper remediation of items.

As healthcare entities often operate or conduct business with patients and vendors across different states, they need to understand and abide by the following key pieces of information for each state: 

  • Dormancy periods
  • Potential exemptions or deductions
  • Report due dates and cut-off dates
  • Due diligence timeframe and threshold values

Take Action

Worried about your company’s compliance with unclaimed property and how to stay updated on the constantly changing rules and regulations? Talk to an expert today.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.


Paola Narez

As a Senior Consulting Manager, Paola serves as a subject matter expert for unclaimed property holders across the country. She utilizes her prior experiences to advocate for organizations during audit examinations, assist with their entrance into state voluntary compliance programs, evaluate unclaimed property risk, work with them to establish initial compliance with the states and maintain ongoing compliance.
Share This Post
Share on facebook
Share on twitter
Share on linkedin
Share on email

E-Invoicing Compliance EMEA Italy VAT & Fiscal Reporting
May 18, 2021
Italy Postpones E-Document Legislation

In September 2020, Italy introduced major changes to the country’s rules on the creation and preservation of electronic documents. These new requirements were expected to be enforced on 7 June 2021. However the Agency for Digital Italy (AGID) has now decided to postpone the introduction of the new e-document rules until 1 January 2022. The […]

North America ShipCompliant
May 14, 2021
Alabama Is Latest State to Permit Direct-to-Consumer Shipping of Wine

Alabama Governor Kay Ivey signed HB 437 into law on May 13, 2021, making Alabama the latest state to legalize direct-to-consumer (DtC) shipping of wine. With this step, only Delaware, Mississippi and Utah continue to prohibit this popular and valuable means of selling wine. Alabama’s new DtC law will not become effective until August 1, […]

Tax Compliance Tax Information Reporting
May 14, 2021
Anatomy of a Due Diligence Letter

What is unclaimed property due diligence? An unclaimed property due diligence letter is an organization’s last chance at contacting an apparent owner and preventing their property from escheatment. Each state or reporting jurisdiction has its own unique set of requirements and standards. Due diligence letters are typically required to be sent 30 to 120 days […]

EMEA VAT & Fiscal Reporting
May 13, 2021
EU Council Approves DAC7 Rules on Digital Platform Tax Reporting

On 22 March 2021 the EU Council approved DAC7, which establishes EU-wide rules meant to improve administrative cooperation in taxation. In addition, the Directive addresses additional challenges posed by a growing digital platform economy. What is DAC7? In 2011, the EU adopted Directive 2011/16/EU on administrative cooperation in the field of taxation in the EU […]

E-Invoicing Compliance EMEA VAT & Fiscal Reporting
May 13, 2021
Russia Introduces Mandatory E-Invoicing From 1 July 2021

Russia introduces a new e-invoicing system for traceability of certain goods on 1 July 2021. Federal Law No. 371-FZ will amend the Russian Tax Code to introduce the new procedure for the traceability system, which will bring the introduction of mandatory e-invoicing for taxpayers dealing with traceable goods. Since its introduction, B2B e-invoicing in Russia […]