On January 30, 2023, the Centers for Medicare & Medicaid Services (“CMS”) released the long-delayed final rule on risk adjustment data validation (“RADV”) audits of Medicare Advantage (“MA”) organizations (the “Final...more
The Situation: In 2016, several Medicare Advantage ("MA") organizations challenged a 2014 final rule promulgated by the Center for Medicare Services ("CMS") that broadly subjected MA organizations to potential liability under...more
The Centers for Medicare & Medicaid Services (CMS) published the Reporting and Returning of Overpayments Final Rule (Final Rule) on February 12, 2016. The Final Rule implements Section 6402(a) of the Affordable Care Act,...more
Effective March 14, 2016, a final rule published last month by the Centers for Medicare & Medicaid Services (CMS) implements the 60-day rule included in the Affordable Care Act (ACA) (31 U.S.C. § 1320a-7k(d)). ACA requires...more
On February 12, 2016, the Centers for Medicare and Medicaid Services (CMS) issued its final rule on the reporting and returning of overpayments by Medicare Part A and Part B providers and suppliers. (In May 2014 CMS had...more
On February 12, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published the long-awaited final rule implementing an Affordable Care Act requirement for healthcare providers and suppliers to report and return...more
The Centers for Medicare and Medicaid Services (CMS) recently issued its final rule for Reporting and Returning of Overpayments (Final Rule). The Final Rule implements section 1128J(d) of the Social Security Act, which...more
The Centers for Medicare & Medicaid Services (CMS) published the Reporting and Returning of Overpayments Final Rule (Final Rule) on February 12, 2016. The Final Rule implements section 6402(a) of the Affordable Care Act which...more
Section 6402(a) of the Affordable Care Act (“ACA”), which was enacted by Congress in 2010, requires a person who has received an overpayment to report and return the overpayment to the Secretary of Health and Human Services,...more
Four long years after first publishing its proposed rule implementing the 60-day overpayment report and return standard imposed by the Patient Protection and Affordable Care Act (ACA), the Centers for Medicaid and Medicare...more
On February 11, 2016, the Centers for Medicare & Medicaid Services (CMS) released the much anticipated final rule on the so-called “60-day rule.” The long road to the final rule began when the Affordable Care Act (ACA)...more