“The 60-day rule has become one of the most significant pillars of an effective compliance plan, said Waltz, who is co-chair of Foley’s Health Care Practice Group. She noted it “has many tentacles that are subject to interpretation.”
Waltz added that in its MPFS rule, CMS is “sticking with their original proposal to revise the definition of identified but adding in a comfort level for providers and suppliers that the six-month investigation period before the 60-day clock starts will be maintained.”
