On February 12, 2016, CMS published the Reporting and Returning of Overpayments Final Rule (Final Rule). The Final Rule takes effect on March 14, 2016. Overall, CMS appears to have listened to stakeholders and acknowledged their comments to the proposed rule. As a result, the Final Rule offers more clarity and reasoned positions than was anticipated. The Final Rule nonetheless will require providers and suppliers to implement various operational changes, some at considerable expense, to satisfy the regulations.
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