Righting an Institutional Wrong: Redefining an Overpayment Through HHS-OIG’s Policy Shift on Zero-Paid Claims
- August 11, 2023
- Stephen Bittinger , K&L Gates LLP
- Melissa Yates , K&L Gates LLP
- Michael Phillips , K&L Gates LLP
The Department of Health and Human Services Office of Inspector General (HHS-OIG) recently enacted a policy in the Corporate Integrity Agreement context that auditors must include underpayments to calculate net overpayments in setting actual overpayments owed. This development signifies an institutional shift to correct the execution and effectuation of congressional intent underlying the Medicare Integrity Program, and contract auditors’ statistical sampling and extrapolation processes.
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