Leg-Reg Update

60-Day Rule
• In 2016 the Centers for Medicare & Medicaid Services finalized a rule
that required Medicare providers to report and repay any
overpayments from the government within 60 days of identifying them.
• Recent enforcement efforts and compliance audits however, have
shown that implementation of the so-called “60-day rule” will continue
to be a topic of interest to health lawyers in 2018, board members said.
“Recent high-profile OIG hospital compliance audits have highlighted
the conflicting positions of providers and the government with respect
to the obligation to identify additional overpayments following an audit
and the appropriate lookback period, given the conflict between the
statutory 4-year claims reopening window for Medicare claims and the
60-day repayment rule’s 6-year lookback period,”
NASL Winter Conference
February 7, 2018
Washington, DC