Today the Centers for Medicare and Medicaid Services (CMS) posted a pre-publication version of a proposed rule regarding the reporting and returning of overpayments.  The proposed rule is intended to address requirements implemented by the Patient Protection and Affordable Care Act (ACA).  Although the proposed rule offers some guidance with regards to some significant issues arising under the ACA changes, for example how the 60 day window to refund or report is determined, it does not address all the intricacies faced by providers.  Hopefully the comment and response process will give further insight as to how to deal with overpayment issues so that providers can be comfortable that they have adequately addressed potential liability.  The proposed rule is posted. If you have any questions about submitting comments to this rule, please let us know.