2019 Compliance Institute (CI)

Criminal and Civil Liability for Overpayments

  • Criminal and Civil Liability for Overpayments

    Gabriel Imperato, Managing Partner, Nelson Mullins Broad and Cassel. David Fuchs, Senior Counsel, Office of the Inspector General, HHS. James Hearty, Chief Compliance Officer, DaVita Inc..

    April 9, 2019

    • The statutory obligation to return a “known overpayment” and its application in criminal and civil enforcement proceedings

    • The basis for liability for “retention of a known overpayment” under the United States False Claims Act

    • The “identification” of a “known overpayment” and the time requirements for disclosure and return of overpayment

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The Health Care Compliance Association (HCCA), is a 501(c)6 non-profit, member-based professional association. HCCA was established in 1996 and is headquartered in Minneapolis, MN. We provide training, certification, and other resources to over 10,000 members. Our members include compliance officers and staff from a wide range of organizations, including hospitals, research facilities, clinics and technology service providers.

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