CMS Finalizes 60 Day Overpayment Rule

CMS recently finalized the 60-day rule regarding reporting and refunding identified overpayments. Morgan Lewis is hosting a webinar to discuss important provisions of this rule and practical compliance tips to account for the rule’s mandates, including the following:

• Is it sufficient to just report an issue and not repay?
• What happens if an organization exceeds eight months in making its repayment? What are the consequences under the circumstances?
• Does the organization always have to look back six years for other improper claims, or can a shorter period suffice?
• What types of matters are subject to cost report reconciliation, and when is it acceptable to wait until a cost report audit to disclose?
• What exactly does CMS expect from organizations to proactively detect potential billing errors, and how will CMS and DOJ enforce the requirements to proactively audit, even where an organization has no credible information of overpayments?