Practical Considerations: A Guide to Voluntary Self-Disclosure, as appeared in Compliance Today

This article, published in Compliance Today, appears here with permission from the Health Care Compliance Association. Authors Anjali Downs (Washington, DC) and Daniel Gospin (Houston) are Associates in the Health Care and Life Science practice.

Following is an excerpt:

Enforcement by federal agencies is on the rise, and chief among the new enforcement mechanisms is the amendment to the False Claims Act by the Affordable Care Act (ACA). The ACA requires, among other things, that all providers and suppliers of services, Medicaid managed care organizations, Medicare Advantage organizations, and prescription drug plans to report and return overpayments to the appropriate state or federal agency or government contractor. Specifically, an organization must report and return the overpayment by the later of 60 days after the date on which the overpayment was identified or the date any corresponding cost report is due.

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