News & Analysis as of

Provider Self-Disclosure Protocol Overpayment Recovery Time Limits

Ruder Ware

Repayment and Self Disclosure of Known Overpayments

Ruder Ware on

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

Ruder Ware

Can Overpayments Create Criminal Liability?

Ruder Ware on

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

Ruder Ware

The Case of the Very Very Impossibly Long, Terrible, Horrible, No Good, Very Bad Day

Ruder Ware on

How Fraud and Abuse Cases Arise in a Medical Practice - It is no secret many doctors work very long days. Some days are worse and some are better than others. As a compliance lawyer, my job is to attempt to prevent...more

Stinson LLP

Center for Medicare & Medicaid Services Announces 60-Day Overpayment Rule

Stinson LLP on

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

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