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Vorys Health Care Advisors

CMS Final Rule on Reporting Overpayments

Posted in CMS, Health Care, Overpayments, Regulations

Yesterday, the Centers for Medicare and Medicaid Services (CMS) published a final rule regarding health care providers’ duty to report and return self-identified Medicare Part A and Medicare Part B overpayments to CMS.  The purpose of this final rule is to provide clarification of the meaning of overpayment identification and the required look-back period for identifying overpayments.  These clarifications significantly impact the ability of health care providers to avoid federal False Claims Act (FCA) liability.

For more information about the final rule, please see the client alert written by Vorys attorneys Victor A. Walton, Jr. and Jacob D. Mahle.

2016-02-11 client alert