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AAMC Submits Comment Letter on CMS Proposed 60-Day Overpayment Rule

April 20, 2012—The AAMC submitted an April 16 comment letter  on the Centers for Medicare and Medicaid Services (CMS) proposed rule, Reporting and Returning of Overpayments, published in the Feb. 16 Federal Register.  The Affordable Care Act (ACA, 111-148 and 111-152) requires that overpayments must be returned within 60 days after the date on which the overpayment was identified.  The AAMC urged CMS to acknowledge that not every incorrect payment should be considered an overpayment; for example, the 60-day clock should not be started when incorrect payments are identified in the course of routine audits that are part of good business practices. The AAMC also said that for cost report payments, such as for the direct graduate medical education payment and the indirect medical education adjustment, the 60 days should not begin when the cost report is filed.


Ivy Baer, J.D., M.P.H.
Senior Director and Regulatory Counsel
Telephone: 202-828-0499


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
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Telephone: 202-903-0806