Blog: compliance investigations

 

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Sally Yates was Already Famous for Changing the Focus of Compliance Investigations – The Yates Memorandum

Posted on April 5, 2017 by
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By now the whole world knows about Sally Yates.  We are likely to see a lot more of her as a central figure in Congressional investigations.  For some of us who deal with compliance investigations, Sally Yates was famous long before her refusal to defend the immigration ban.  She was the author of the famous […]

Exercising Reasonable Care to Identify and Address Potential Overpayments

Posted on April 5, 2017 by
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When the Center for Medicare and Medicaid Services (CMS) finally issued final regulations under the 60-day repayment rule, it implemented a new standard requiring a provider to affirmatively exercise reasonable diligence to identify potential overpayments.  This was a change from the proposed regulations that held providers to a much lower affirmative duty to exercise diligence […]