On February 12, 2016, the Centers for Medicare & Medicaid Services (CMS) published a long-awaited final rule (Final Rule) implementing the Affordable Care Act’s (ACA’s) statutory requirement that certain overpayments be reported and returned within 60 days of being identified. The Final Rule will take effect on March 14, 2016. The following critical analysis describes the Final Rule in the context of the ACA’s underlying statutory requirement, contemplates legal issues implicated by the Final Rule, and raises considerations for providers and suppliers that revisit their compliance functions after the Final Rule.