CMS proposes revised Medicare overpayment rule, clarifies reporting obligations

CMS issued a proposed rule revising the Medicare overpayment reporting and refund process. The changes aim to clarify the 60-day repayment timeline and define when a provider has 'identified' an overpayment, which triggers the refund obligation. This rule directly addresses provider confusion following court cases that questioned CMS's enforcement authority. The proposal also refines the lookback period for overpayment identification. The comment period will open soon; billing teams should review internal compliance protocols for identifying and reporting overpayments to prepare for the final rule.