Medicare Overpayments: Analyzing the CMS 60-Day Rule

Reporting and Refunding Overpayments for Providers, Suppliers, Drug Plan Sponsors, and Medicaid MCOs

CMS comment period closes April 16

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

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Conducted on Thursday, April 12, 2012

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE course will provide guidance to counsel for healthcare providers, suppliers, drug plan sponsors and Medicaid managed care organizations (MCOs) on the new CMS proposed rules on reporting and returning Medicare overpayments.


The Centers for Medicare & Medicaid Services (CMS) recently published its proposed rule implementing the 60-day Medicare overpayment reporting requirement under the Affordable Care Act (ACA).

CMS addresses the timing of identifying an overpayment, reconciliation, sets up a process of reporting and refunding the overpayment, and increases the lookback period. Under the proposed rule, failure to meet the requirements to report and return overpayments can result in liability under the False Claims Act.

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

Listen as our authoritative panel of health law practitioners reviews the overpayment obligations under ACA, examines CMS’ proposed rule—including its impact on Medicaid—and offers practical steps for providers and suppliers to take in response to the proposed rule.



  1. Review of overpayment obligations under ACA
  2. CMS’ proposed rule
    1. Identification of overpayments
    2. Limited applicable reconciliation
    3. Refund processes
    4. Ten year lookback and claims reopening periods
  3. Application/impact on Medicaid
  4. Strategies for providers and suppliers


The panel will review these and other key questions:

  • What are a provider's reporting and refunding of overpayment obligations under the ACA?
  • How will the existing voluntary refund process be incorporated into the implementation of the 60-day rule?
  • What steps can providers and suppliers take in response to the proposed rule?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Roth, Robert
Robert L. Roth

Hooper Lundy & Bookman

Mr. Roth advises clients on matters arising under Medicare and Medicaid, focusing on payment, compliance, and...  |  Read More

James G. Sheehan
James G. Sheehan
Executive Deputy Commissioner and Chief Integrity Officer
Human Resources Administration of New York City

He is responsible for addressing fraud and improper payments involving providers, contractors and recipients, and for...  |  Read More

Paul A. Deeringer
Paul A. Deeringer

Hooper Lundy & Bookman

His practice involves healthcare-related business transactions and general corporate representation, including...  |  Read More

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