Law360 Features Article by Linda Baumann and Hillary Stemple on CMS Overpayment Rule

In the Law360 article “Ensuring Compliance with CMS 60-Day Overpayment Rule,” Arent Fox Health Care partner and leader of the Health Care group in the DC office Linda Baumann, and Health Care associate Hillary Stemple, discuss the critical importance of the 60-day overpayment rule for health care providers and how to comply.

The Affordable Care Act requires all Medicare and Medicaid overpayments to be reported and returned by the later of 60 days after the date the overpayment was identified or the date any corresponding cost report is due (if applicable). Failure to comply can lead to devastating financial and other penalties.

Earlier this year, the Centers for Medicare and Medicaid Services (CMS) issued the final regulations of the 60-day overpayment rule to clarify some of the initial confusion surrounding certain aspects of the law.

Linda and Hillary review some of the key issues, such as when overpayments are “identified,”  what constitutes “reasonable diligence,” and the required lookback period, that the final regulations address, and provide recommendations to help reduce exposure.

Click here to read the full article.
 

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