tci Medicare Compliance & Reimbursement - 2016 Issue 5
Compliance: Take a Closer Look at 3 Other 60-Day Rule Provisions
You’re still subject to the rule, even if the overpayment wasn’t your fault. The Centers for Medicare & Medicaid Services (CMS) isn’t giving you much leeway when it comes to the 60-day overpayment rule. In fact, CMS confirmed in the final rule its staunch position on the 60-day rule’s repayment requirements, regardless of how or why the overpayment occurred. 1. Third-Party Anti-Kickback Violations: In the rule’s preamble, CMS affirmed its position that compliance with the Anti-Kickback Statute is a condition of payment and, therefore, you could have a repayment obligation arising from a third...
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