BC Advantage - 2017 Issue 1

To Disclose or Not to Disclose... That's the Question

The biggest questions I receive these days are in regard to handling potential overpayments regarding internal or external audits is whether or not the errors constitute a self-disclosure protocol. The short answer is, avoid this process unless you have verifiable fraudulent activity to report.Section 1128J(d) of the Act created an express duty to refund and report Medicare and Medicaid overpayments "by the later of" 60days after the overpayment was "identified" or the date the cost report is due. ... The Final Rule only applies to overpayments from traditional Medicare- Parts A & B.The rule includes very specific language...

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