We Might Have Been Overpaid. What Should We Do? Fraud and compliance risks from the retention of overpayments under government health benefit programs
June 12, 2008
When is repayment required under Medicare and Medicaid even if a refund demand hasn’t been made?
How far back should I go?
What if an innocent billing mistake or inaccurate pricing proposal results in an overpayment?
What penalties apply to parties who do not voluntarily disclose and refund overpayments?
How can I pin down civil False Claims Act and criminal prosecution risks?
What is the lesson of the East Tennessee Heart Consultants settlement, where the False Claims Act and criminal fraud enforcement were used against alleged knowing retention of funds required to be repaid?
What difference does it make if the payment was made under a Medicare or Medicaid managed care program?
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