Tag: Joshua Skora

A. My last column explained CMS's final rule clarifying the 60-day rule, which allows a supplier up to six months to quantify an overpayment once it's identified. Once the supplier quantifies the overpayment, it has 60 days to report and refund the overpayment. However, there is little, if any, guidance on how in-depth an investigation must be to quantify the scope of an overpayment. Take the following hypothetical: A supplier has a sales representative in each of the five states it conducts...