Posted on April 5, 2017 by Ruder Ware Alumni
Blog
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 […]
Posted on March 17, 2017 by Ruder Ware Alumni
Blog
In 2013, the HHS Office of Inspector General issued revised protocols outlining the process through which health care providers are able to self-disclose and resolve potential liability under the OIG’s civil monetary penalty (CMP) authorities. The 2013 Self Disclosure Protocols (SDP) clarified the process of self-disclosure and provided answers to some of the questions previously […]