This morning the Centers for Medicare and Medicaid Services issued a final rule that addresses the obligation of health care providers and suppliers to report and return overpayments by the later of 60 days from the date an overpayment is identified or the due date of any corresponding cost report.
According to the CMS Fact Sheet announcing the final rule, a person has identified an overpayment when the person has or should have, through the exercise of reasonable diligence, determined that the person has received an overpayment and quantified the amount of the overpayment. The final rule includes that an overpayment must be reported and returned if identified within six years of the date the overpayment was received.
We are preparing a more detailed analysis of this final rule, which will be posted shortly. We will also hold a teleconference in the next few days for interested parties to learn more about the nuances of this final rule and the obligation of providers and suppliers to report and return overpayments. We will post as soon as possible the date and time of this teleconference.