Lexology August 23, 2024
In response to comments on the 2022 proposed changes to the overpayments regulation, the Centers for Medicare & Medicaid Services (CMS) proposed additional changes to the overpayment rule to clarify that the obligation to report and return requires quantification of the overpayment as part of identification. However, CMS proposed a strict time period for conducting reviews of overpayment issues. Under the proposed rule, the statutory 60-day clock would start to run either on the date of completion of the investigation or 180 days from the date on which the initial overpayment was identified, whichever is earlier. This proposal raises several questions and appears contrary to the overpayment statute.
In Depth
BACKGROUND AND PRIOR PROPOSED RULE
On July 31, 2024, CMS...
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