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The FCA Payback on Medicare Overpayments

Client Alert | less than 1 min read | 03.07.16

In February, the Centers for Medicare & Medicaid Services issued a final rule governing the reporting and return of overpayments for items and services reimbursed under Medicare Parts A and B. A new alert discusses how the final rule clarifies when an overpayment has been identified and how efforts precedent to identifying such overpayments will be important to future enforcement efforts under the FCA.

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Client Alert | 2 min read | 02.03.26

CMS Doubles Down on RADV Audit Changes

On January 27, 2026, the Centers for Medicare and Medicaid Services (CMS) released a Health Plan Management System (HPMS) memo that provided a long-awaited update on how the agency plans to approach previously announced Risk Adjustment Data Validation (RADV) audits for Payment Years (PY) 2020-2024. The memo is the agency’s most comprehensive statement on the subject since September 25, 2025, when the Northern District of Texas vacated the 2023 RADV Final Rule. The memo makes clear that, while CMS has made certain operational adjustments in response to concerns expressed by Medicare Advantage Organizations (MAOs), the agency is largely pressing forward with the accelerated audit strategy announced in May 2025....