Report on Medicare Compliance 30, no. 28 (August 2, 2021) - When a hospital realized it had been billing for annual wellness visits without documentation of opioid and substance use screening, it wasn’t a heavy lift to...more
The 60-day repayment rule adopted as part of the Affordable Care Act is a very strong arrow in the quiver of federal enforcement agencies. Under the 60-day rule a known overpayment can become a False Claim if it is not repaid...more
We hear a lot about potential liability under the False Claims Act (FCA) for the failure to repay overpayments within 60 days of discovery. Focus on the 60-day rule has taken focus away from the potential for criminal charges...more
The HHS Office of Inspector General offers providers an opportunity to self-disclose certain violations in exchange for avoiding some of the more draconian penalties that may otherwise apply under applicable regulations. ...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
Medicare Part A and B providers and suppliers should take note of new regulations recently issued by the Centers for Medicare & Medicaid Services that implement the Affordable Care Act’s 60-day rule on reporting and returning...more
On February 11, 2016, the Centers for Medicare and Medicaid Services (“CMS”) released for publication its final rule for the Reporting and Returning of Overpayments under Medicare Part A and Part B (the “Final Rule”). The...more