Explains how the Medicare and Medicaid 60-day overpayment rule (42 U.S.C. 1320a-7k(d)) turns a stalled internal audit into reverse false claim liability under the False Claims Act, 31 U.S.C. 3729(a)(1)(G). Reviews two DOJ settlements from September and October 2026 in which providers identified overpayments and did not return them. Closes with an operator checklist for reviewing, documenting, and returning identified overpayments.
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Andrew Hillman (2026) studied this question.
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