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Overpayment Medicare

McDermott Will & Emery

Healthcare Regulatory Check-Up Newsletter | March 2025 Recap

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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

Polsinelli

Federal Court Finds False Claims Act Penalty Unconstitutionally Excessive

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On February 26, 2025, the U.S. District Court for the Northern District of Texas issued a significant False Claims Act (FCA) ruling in United States of America ex rel. Cheryl Taylor v. Healthcare Associates of Texas, LLC,...more

Baker Donelson

Looking Back at 2024: Key Health Care Regulatory Legal Developments in Fraud and Abuse, Compliance, and Enforcement

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The health care regulatory space realized significant regulatory and enforcement developments in 2024 that are influencing how providers and industry stakeholders approach various compliance measures and enforcement...more

ArentFox Schiff

Investigations Newsletter: First Circuit Joins Sixth and Eighth Circuits in Adopting Heightened, But-For Causation Standard for...

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First Circuit Joins Sixth and Eighth Circuits in Adopting Heightened, But-For Causation Standard for AKS-Based FCA Claims - On February 18, the US Court of Appeals for the First Circuit became the latest court to agree...more

Proskauer - Health Care Law Brief

CMS Publishes Final Rule, Effective January 1, 2025, Addressing the Requirements for Reporting and Returning Overpayments

The standard for an “identified overpayment” under Medicare Parts A–D now aligns with section 1128J(d)(4)(A) of the Social Security Act, which incorporates by reference the Federal False Claim Act’s (the “FCA”) “knowledge”...more

Dentons

Ep. 45 – Update Your Return of Overpayments Policy to Align With CMS Changes to the 60-day Rule

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Providers are required by federal law to return Medicare and Medicaid overpayments within 60 days of identifying the overpayment or they can be liable under the False Claims Act. Since 2016, providers have relied on Centers...more

Mintz - Health Care Viewpoints

EnforceMintz — Medicare Advantage and Part D Programs to Remain in the Enforcement Spotlight in 2025

As government scrutiny and enforcement targeting the Medicare Advantage (Medicare Part C) program continued in 2024, the industry’s response to agency actions escalated. Last year also resulted in the first sizable Part D...more

Whiteford

Navigating New Medicare Overpayment Rules and Practical Tips to Comply

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On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) finalized the Medicare regulations interpreting the federal 60-day overpayment refund requirement (the Overpayment Statute) for Medicare Parts A and B as...more

Baker Donelson

2025 Medicare Physician Fee Schedule: Payment and Overpayment Policies

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On December 9, 2024, the Centers for Medicare & Medicaid Services' (CMS's) Calendar Year 2025 Physician Fee Schedule Final Rule (the Final Rule) was published in the Federal Register. The Final Rule includes noteworthy...more

King & Spalding

OIG Report Finds that the Medicare Program Improperly Paid Acute-Care Hospitals for Outpatient Services Provided to Hospice...

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On November 12, 2024, OIG published a report concluding that the Medicare program overpaid acute-care hospitals an estimated $190 million over five years for outpatient services provided to hospice enrollees....more

Goodwin

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

Goodwin on

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

Holland & Knight LLP

Final Medicare Overpayment Rules a Mixed Bag for Providers

Holland & Knight LLP on

The Centers for Medicare & Medicaid Services (CMS) released highly anticipated updates this month to the Medicare regulations interpreting the federal 60-day overpayment refund requirement (the Overpayment Statute). The...more

Husch Blackwell LLP

Hospice Insights Podcast - Meet the New Laws, Same as the Old Laws: Overpayment Recoupment Update

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Hospices that have been audited have to decide how to address any alleged overpayment identified by the auditor, whether through a voluntary repayment, recoupment, or applying for an extended repayment schedule. CMS recently...more

Foley & Lardner LLP

Medicare Overpayments: CMS Issues Final Regulations Implementing Changes to 60-day Refund Rule

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On Friday, November 1, 2024, the Center for Medicare & Medicaid Services (CMS) issued the display copy of the final rule interpreting the 60-day Refund Rule for Medicare Parts A/B (Traditional Medicare) and C/D (Medicare...more

McCarter & English, LLP

CMS Proposes Further Changes to Medicare Overpayment Rule

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The Centers for Medicare & Medicaid Services (CMS) recently published a proposed rule, 89 FR 61596, that revives portions of a 2022 proposal to amend the Medicare Overpayment Rule. The 2024 proposed rule comes after...more

Dentons

Ep. 32 – An Easy Audit Tip to Help Avoid Overpayments

Dentons on

Looking for a simple, easy-to-implement way to lower your risk of overpayments? We have one on this week’s podcast!...more

King & Spalding

OIG Audit Finds Medicare Overpaid Hospitals an Estimated $79 Million for Enrollees Who Had Received Mechanical Ventilation

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On August 12, 2024, OIG announced the results of an audit of payments made to hospitals for inpatient claims with the Medicare Severity Diagnosis-Related Groups (MS-DRGs) that require ninety-six hours of consecutive...more

McDermott Will & Emery

CMS Revives, Expands Proposed Changes to Medicare Overpayment Rule

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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...more

Baker Donelson

CMS Proposes Significant Changes to the Medicare Shared Savings Program and 60-Day Rule

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Under the CY 2025 Medicare Physician Fee Schedule (PFS) proposed rule, CMS proposes several modifications to the Medicare Shared Savings Program (MSSP) that would become effective in performance year 2025. CMS also proposed...more

The Volkov Law Group

Gentiva Pays $19.4 Million for False Claims Act Violations Involving Hospice Care

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Gentiva, the renamed former Kindred at Home, agreed to pay $19.4 million to resolve claims that its predecessor company, Kindred at Home and related companies, violated the False Claims Act by retaining overpayments for...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

Polsinelli

Provider Reimbursement Disputes Go Back to 1984 Following Supreme Court’s Regulatory Reset

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One could forgive the healthcare industry for thinking someone drove Doc Brown’s DeLorean time machine through One First Street when it awoke on Friday, June 28, to a blast from the past....more

King & Spalding

OIG Report Details Weaknesses in Enforcement of Two-Midnight Rule

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CMS estimates that between 2017 and 2021, Medicare Part A improperly paid $23.9 billion for inpatient hospital stays, with $7.8 billion attributable to short stays that did not qualify for Medicare Part A. On June 13, 2024,...more

K&L Gates LLP

What's Been Missing: District Court Orders the Government to Produce Complete Universe of Claims in Provider's Due Process...

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On 5 March 2024, in an issue of first impression in the District of South Carolina, a district court judge overseeing judicial review of a final agency decision in a Medicare claims appeal ordered the Government to complete...more

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