Tag: self disclosure

CMS Stark Law Self Disclosure – New Form and Process for Self Disclosing Stark Law Violations

Posted on by admin
The Centers for Medicare and Medicaid Services (CMS) has issued new forms and procedures for provider self-disclosure of Stark Law violations. The new material is intended to streamline the process that permits providers to self-disclose Stark Law violations.  The process is applicable to violat...

Can Overpayments Create Criminal Liability?

Posted on by admin
We hear a lot about potential liability under the False Claims Act (FCA) for the failure to repay overpayments within 60 days of discovery. Focus on the 60-day rule has taken focus away from the potential for criminal charges for retaining known overpayments.  Section 1128B(a)(3) of the Social S...