Compliance concerns after CMS 60-day overpayment rule

Publication March 10, 2016

This month, the final rule takes effect that clarifies the Affordable Care Acts’ requirement that healthcare providers must report and return overpayments within 60 days after identifying the overpayment or the date any applicable corresponding cost report is due, whichever is later.

The final rule, 81 Fed. Reg. 7654 (Feb. 12, 2016), relaxes the Centers for Medicare and Medicaid Services’ proposed rule by shortening the proposed lookback period and giving providers time to quantify amounts, although it maintains a strict approach that all overpayments — no matter how small — will require investigation and action.

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