PODCAST: Williams Mullen's Benefits Companion - SECURE 2.0 Act - More Relief for Plan Administrators
Recent Tenth Circuit Decision in John Q Hammons Fall Following SCOTUS’ Decision in Siegel v. Fitzgerald Could Result in Significant Refunds for Certain Chapter 11 Debtors
Nuts and Bolts of a Repayment Investigation: Keys to Conducting Investigations Under the 60-Day Repayment Rule
Hospice Audit Series: The Latest Developments and Strategies for Success in the Ever-changing Audit Landscape
In the context of Medicare Advantage (“MA”) reform initiatives, we previously addressed the Centers for Medicare & Medicaid Services’ (“CMS”) December 27, 2022 proposal to amend its regulations set forth at 42 C.F.R. §...more
The Centers for Medicare & Medicaid Services (CMS) proposed a rule late last year that would impose standards on healthcare providers and suppliers to report and return overpayments from Medicare that mirror aspects of the...more
On June 29, 2021, the Department of Justice (DOJ) announced a settlement with California skilled nursing facility operator Plum Healthcare Group LLC and facility Azalea Holdings LLC dba McKinley Park Care Center (Plum) to...more
Report on Medicare Compliance 29, no. 42 (November 23, 2020) - Medicare administrative contractors (MACs) will be coming to 911 hospitals for overpayments caused by unreported manufacturer credits for recalled or...more
The U.S. District Court for the District of Columbia handed down a major victory to Medicare Advantage issuers on September 7, 2018, vacating a 2014 CMS regulation relating to Medicare Advantage overpayments. ...more
The District Court for the Middle District of Tennessee held on June 22, 2017, that the timing requirements related to a physician's certification of need for home health services were not "material" to the Centers for...more
On May 6, 2016, CMS published a notice (Notice), required under the Paperwork Reduction Act (PRA), seeking public comment on its plans to revise the information collected under the Medicare Self-referral Disclosure Protocol...more
The Affordable Care Act (sometimes referred to as Obamacare) included a requirement for providers to report and return all Medicare and Medicaid overpayments within 60 days of identification. Although this requirement has...more
On February 12, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule that explains the requirements for providers and suppliers reporting and returning overpayments under Medicare Parts A & B (the...more
The Centers for Medicare and Medicaid Services (“CMS”) has clarified the reporting requirements and lookback period for overpayments from Medicare Parts A and B in Final Rule 6037 (“Final Rule”), issued by CMS on February 12,...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
CMS provides some clarity in Affordable Care Act final rule, but questions remain, complicating compliance efforts. On February 12, 2016, the Centers for Medicare & Medicaid Services (CMS) published a final rule (Final...more
On February 12, 2016, CMS published a final rule addressing compliance with Section 1128J(d) of the Social Security Act. Section 1128J(d), which was added when the Affordable Care Act was enacted on March 23, 2010, imposes a...more
On February 11, 2016, CMS released its much anticipated final overpayment reporting and refunding rule for Medicare Parts A and B (Final Rule). The Final Rule implements Section 6402(a) of the Affordable Care Act (ACA),...more
On February 11, 2016, the Center for Medicare and Medicaid Services (“CMS”) clarified several issues with regard to Medicare reporting and returning of self-identified overpayments. The Affordable Care Act (the "ACA"),...more
The final rule relaxes the requirements on “identification” and look-back period. The Centers for Medicare & Medicaid Services (CMS) has released its long-awaited final rule related to the reporting and refunding of...more
In Kane ex rel. U.S. v. Healthfirst, Inc., the federal district court for the Southern District of New York (District Court or Court) provided on August 3 the first and long-awaited interpretation as to when a health care...more
The Patient Protection and Affordable Care Act (“PPACA”), signed into law on March 23, 2010, included a provision (the “Report and Refund Mandate”), broadly requiring health care providers, suppliers, Part D plans and managed...more
One of the most challenging compliance changes brought about by the Affordable Care Act (ACA) is the provision mandating the reporting and refunding of Medicare and Medicaid overpayments within 60 days of the date they are...more
Medicare overpaid the home health industry $2 billion between January 2011 and December 2012, according to a recent report by the U.S. Department of Health and Human Services, Office of Inspector General (OIG). The OIG’s...more
The Centers for Medicare & Medicaid Services continues to take an expansive view of the overpayment refund requirement, which in turn can give rise to False Claims Act liability for Medicare Advantage Organizations and Part D...more