Digging Deeper in Your Audits: An Investigative Approach to Effective Compliance, the 60-Day Rule, and Identifying Overpayments (2020 Fraud Single Session)

21. Digging Deeper in Your Audits: An Investigative Approach to Effective Compliance, the 60-Day Rule, and Identifying Overpayments (Single Session Taken from the 2020 Fraud and Compliance Forum)

Adam Hepworth
Lori Laubach

  • Knowing when to audit (and when to refund)
    • Auditing is a core component of an effective compliance program (Sentencing Guidelines/DOJ/HHS-OIG) and is critical for meeting federal obligations under the 60-day rule
  • Structuring the audit, getting it done, and moving forward
    • Early legal assessment is essential to identify the applicable ruleset and guidance. Audit design may be sensitive to eventual refund obligations (e.g., MAC refund vs. OIG self-disclosure vs. Medicaid self-disclosure). Discuss tips for dealing with data, records review, and statistical extrapolation
  • Meeting legal obligations while maximizing legal protections
    • How to identify when there is an overpayment (relevance of Escobar). Importance of transparency in self-disclosures. How to maintain attorney-client privilege
Continuing Education Credits are available for this session. For CLE credits, you can earn 1.0 credit hours on a 60-Min Calculation and 1.2 credit hours on a 50-minute Calculation. For CPE and CCB, you can earn 1.2 credit hours for this session.