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False Claims Act (FCA) Centers for Medicare & Medicaid Services (CMS) Patient Protection and Affordable Care Act (PPACA)

McDermott Will & Schulte

Healthcare Regulatory Check-Up Newsletter | June 2025 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights regulatory activity for June 2025, including a new Centers for Medicare & Medicaid Services (CMS) innovation model; proposed rules with significant...more

McDermott Will & Schulte

Healthcare Regulatory Check-Up Newsletter | April 2025 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights regulatory activity for April 2025, including Centers for Medicare & Medicaid Services (CMS) updates to Medicare Advantage (MA) and other Medicare programs....more

McDermott Will & Schulte

Healthcare Regulatory Check-Up Newsletter | March 2025 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights key regulatory and enforcement activity for March 2025. This month features: - Noteworthy enforcement actions demonstrating that the Anti-Kickback Statute...more

Kaufman & Canoles

Medicare’s 60-Day Rule

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The Centers for Medicare & Medicaid Services (CMS) finalized significant updates to the Medicare 60-Day Rule, which governs how providers and organizations must handle overpayments. Taking effect January 1, 2025, these...more

Goodwin

Watch the Clock! CMS Makes Important Changes to Medicare Overpayment Rules

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The Centers for Medicare & Medicaid Services (CMS) recently made meaningful changes to its regulations interpreting the Affordable Care Act’s (ACA’s) so-called “60-day Rule,” which requires Medicare providers to affirmatively...more

Robinson+Cole Health Law Diagnosis

CMS Finalizes Standard for Identifying Overpayments and Grace Period for Investigations of Related Overpayments

As part of its 2025 Physician Fee Schedule Final Rule (PFS Rule), the Centers for Medicare & Medicaid Services (CMS) finalized two crucial updates to federal Medicare overpayments regulations (sometimes referred to as the...more

Epstein Becker & Green

Affordable Care Act Overpayments in the CY 2025 Medicare Physician Fee Schedule Proposed Rule: Implications for False Claims

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Stakeholders are continuing to analyze the implications of the mammoth proposed rule on “Medicare and Medicaid Programs: [Calendar Year (CY)] 2025 Payment Policies under the Physician Fee Schedule and Other Changes to Part B...more

Stevens & Lee

Welcome to the Post-Chevron World: HHS on the Defensive

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The Supreme Court’s recent ruling in Loper Bright Enterprises v. Raimondo (and its companion case, Relentless v. Department of Commerce), in which it overruled the Chevron doctrine, has received a great deal of attention...more

Foley & Lardner LLP

Medicare Overpayments: CMS Proposes Regulation Establishing Six Month Suspended Deadline for 60-Day Refund Rule

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The 60-day Refund Rule, created by the 2010 Affordable Care Act, requires providers to report and return Medicare and Medicaid overpayments within 60 days of identifying them. See Section 1128J(d) of the Social Security Act,...more

Mintz - Health Care Viewpoints

CMS Proposed Rule for Refunding Overpayments Would Align With False Claims Act “Knowledge” Standard

The Centers for Medicare & Medicaid Services (CMS) proposed a rule late last year to harmonize the standard it would apply for providers to identify and refund overpayments with the “knowledge” standard under the False Claims...more

Foley & Lardner LLP

Will CMS’s Proposed Rule on “Identified Overpayments” Increase Reverse FCA Cases?

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On December 27, 2022, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule which, in part, seeks to amend the existing regulations for Medicare Parts A, B, C, and D regarding the standard for when an...more

Benesch

Dialysis & Nephrology Digest - December 2022

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Benesch: AKS claims against Azura dropped; FCA allegations to continue with DOJ intervention - The DOJ filed an Amended Intervenor Complaint in Aug. alleging between 2012 and 2018, Fresenius Medical Care’s business unit,...more

McDermott Will & Schulte

Healthcare Regulatory Check-Up Newsletter | August 2022 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights significant enforcement activity between July 21 and August 20, 2022. Key updates include a case in which the US Court of Appeals for the Eighth Circuit...more

ArentFox Schiff

Investigations Newsletter: New DC Circuit Ruling Impacts Medicare Advantage Plans and FCA Enforcement

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In a unanimous opinion, the DC Circuit reversed a successful challenge brought by UnitedHealth (United) and other Medicare Advantage insurers to vacate a Medicare Advantage Overpayment Rule. The Overpayment Rule requires that...more

King & Spalding

D.C. Circuit Rejects UnitedHealthcare’s Challenge to the Medicare Advantage 60-Day Overpayment Rule

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The D.C. Circuit Court overturned UnitedHealthcare’s victory in the lower court that resulted in vacatur of the Medicare Advantage 60-day overpayment rule (the Overpayment Rule). Last week, the D.C. Circuit Court held that...more

Health Care Compliance Association (HCCA)

Credible Information Is Heart of 60-Day Rule; OIG: Self-Disclosure Pauses the Clock

Report on Medicare Compliance 30, no. 28 (August 2, 2021) - When a hospital realized it had been billing for annual wellness visits without documentation of opioid and substance use screening, it wasn’t a heavy lift to...more

Bricker Graydon LLP

Skilled nursing facility operator settles false claims case involving allegations that the company failed to report and return...

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On June 29, 2021, the Department of Justice (DOJ) announced a settlement with California skilled nursing facility operator Plum Healthcare Group LLC and facility Azalea Holdings LLC dba McKinley Park Care Center (Plum) to...more

Bass, Berry & Sims PLC

Recent FCA Cases Emphasize the Importance of Diligently Addressing Potential Overpayments

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A common feature of False Claims Act (FCA) litigation is the pursuit of liability under the FCA’s so-called “reverse” false claims provision, 31 U.S.C. § 3729(a)(1)(G).  Reverse false claims liability applies when a person or...more

Rivkin Radler LLP

Medtronic Settles Kickback And Open Payments Violations For $9.2M

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The U.S. Department of Justice (DOJ) announced on October 29 that Medtronic USA Inc. agreed to pay $8.1 million to settle allegations that it violated the False Claims Act (FCA) and federal Anti-Kickback Statute by paying...more

Holland & Knight LLP

Healthcare Law Update: October 2019

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In recent years, the healthcare industry has been turning greater attention to the need to engage or involve patients in developing new technologies and systems to improve healthcare delivery. These patient engagement...more

Foley & Lardner LLP

Healthcare Law Review: Overview of the U.S. Healthcare System

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The U.S. healthcare industry remains at a crossroads. The healthcare reform legislation passed under President Barack Obama in 2010, officially called the Patient Protection and Affordable Care Act (ACA) but widely referred...more

Ruder Ware

Apply the 60-Day Rule to Medicaid Overpayments

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The Affordable Care Act requires any person who has received an overpayment from certain defined government health programs to report and return the overpayment within 60 days after the overpayment is identified. If an...more

Bricker Graydon LLP

A 60-Day Overpayment Refund Rule update

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The 60-Day Overpayment Refund Rule (60-Day Rule) was enacted as Section 6402 of the Affordable Care Act (ACA) on March 23, 2010. ...more

Jones Day

D.C. District Court Vacates 60-Day Medicare Advantage Overpayment Rule

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The Situation: In 2016, several Medicare Advantage ("MA") organizations challenged a 2014 final rule promulgated by the Center for Medicare Services ("CMS") that broadly subjected MA organizations to potential liability under...more

Arnall Golden Gregory LLP

Court Nixes CMS’s Negligence Standard for Applying False Claims Act Liability for Failure to Report and Return Overpayments

In what has become widely known as the “60-day rule,” the Affordable Care Act (ACA) requires that Medicare and Medicaid overpayments be reported and returned within the later of the date which is 60 days after the date on...more

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