CMS 60-Day Rule: Reporting and Refunding Overpayments for Providers and Suppliers One Year Later

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, April 5, 2017

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will provide counsel for healthcare providers and suppliers with experiences and perspectives on complying with the Center for Medicare and Medicaid Services’ (CMS) rule on reporting and returning Medicare overpayments.


In 2016, the CMS issued its long-awaited final rule on the mandatory report and return overpayments rule, known as “the 60-day rule.” Medicare and Medicaid providers, suppliers and managed care contractors are to report and return an overpayment within 60 days of their identification. Retention of an identified overpayment beyond that 60-day period risks liability under the False Claims Act.

Under the rule, the clock starts when a provider has identified an overpayment, which is defined as “when the person has, or should have through the exercise of reasonable diligence, determined that the person has received an overpayment and quantified the amount of the overpayment. A person should have determined that the person received an overpayment and quantified the amount of the overpayment if the person fails to exercise reasonable diligence and the person in fact received an overpayment.”

Counsel to healthcare providers and suppliers must understand the rule, advise on implementing policies and procedures for reporting and refunding identified overpayments, and implement audit approaches.

Listen as our authoritative panel of healthcare attorneys examines the CMS rule—including its impact on Medicaid—and offers practical steps for providers and suppliers to take in response to the final rule.



  1. CMS’ final rule
    1. Identification of overpayments
    2. Refund processes
    3. Six-year lookback
  2. Strategies for providers and supplies


The panel will review these and other key issues:

  • When is an overpayment identified and what constitutes reasonable diligence?
  • What policies and procedures should providers and suppliers implement to ensure compliance with the final rule?


Anderson, Jana
Jana Kolarik Anderson

Foley & Lardner

Ms. Anderson focuses on health law issues, including federal and state fraud issues such as anti-kickback,...  |  Read More

Wright, Jill
Jill S. Wright

Special Counsel
Foley & Lardner

Ms. Wright’s practice focuses on healthcare fraud and abuse and compliance issues, including the federal...  |  Read More

Other Formats
— Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video