Understanding the Decision Points of Self-Disclosures and Repayment Obligations
Duration: 60 Minutes
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This presentation will provide a general overview related to the process of disclosing self-identified Medicare overpayments. More specifically, it will walk attendees through the current regulatory framework governing reporting and returning obligations. Additionally, discussion will also include insights on how to conduct an internal review and the decisions involved such as determining when to report and where to disclose.
01/12/2018 10:00 AM01/12/2018 04:00 PMTraining Topic: Understanding the Decision Points of Self-Disclosures and Repayment ObligationsInstructor: Jay P. Anstine
Historically, providers and suppliers enrolled in federal government healthcare programs have reconciled and returned overpayments through various post-payment audits. Additionally, these same entities have voluntarily returned self-identified overpayment through various self-disclosure methods made available to them. When Congress passed the Fraud Enforcement Recovery Act of 2009 ("FERA"), these self-identified disclosures went from strongly encouraged to a mandatory obligation. FERA took the position that to keep the money constituted a "reverse false claim" under the False Claims Act (FCA) (31 U.S.C. 3729-3733). Additionally, new repayment obligations surfaced with the passage of the Patient Protection and Affordable Care Act of 2010.
Objectives of the Presentation
Overview of reporting and repayment obligations
The Medicare 60-Day Overpayment Rule
The OIG Self Disclosure Protocol
The CMS Self-Referral Disclosure Protocol
Strategies for conducting an internal review
The reporting process
The repayment process
Questions and answers
Why Should you Attend
If a Medicare participating provider or supplier fails to report and return an overpayment, the entity could face significant fines and penalties under the False Claims Act and the Civil Monetary Penalties Statute (42 U.SC. 1320a-7a). This presentation is designed to help guide you through the process to determine if you have an overpayment to help proactively protect your organization.
Who will Benefit
This presentation will help any compliance professional working for a healthcare employer.