Lexology November 25, 2024
False Claims Act liability considerations for healthcare providers navigating internal investigations and refunds
In the Calendar Year 2025 Medicare Physician Fee Schedule, the Centers for Medicare & Medicaid Services (CMS) finalized changes to the Medicare Parts A and B Overpayment Rule that were proposed in two prior rulemakings. This alert provides a summary of the key changes that will impact how healthcare providers and suppliers assess potential overpayment scenarios, conduct internal investigations, and plan for appropriate refunds.
Alignment with the False Claims Act
The definition of “knowing” and “knowingly” in the regulation has been aligned with the Federal False Claims Act standard. This means that an overpayment is identified if a provider or supplier has actual knowledge, acts in deliberate...
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