Special Statutory Provisions related to Clinical R When is an overpayment considered “identified” to start the 60-day clock for determining the date a refund is due?According to the Centers for Medicare and Medicaid Services (“CMS”), an overpayment is “identified” when the provider or supplier has actual knowledge of the existence of the overpayment or acts in reckless disregard or deliberate ignorance of the existence of the overpayment. Providers should act quickly to reasonably investigate potential overpayments and conduct such investigations with deliberate speed to avoid potential liability.3 | |
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