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The New 60-Day Repayment Rule: What’s New? What’s the Same? What Does It Mean?

Brief

Husch Blackwell attorneys Bryan Nowicki and Andrew Brenton present a short presentation explaining CMS’s 2026 revision to the Medicare 60‑Day Repayment Rule, which redefines when an overpayment is "identified," shifts the 60‑day repayment start, and changes internal‑investigation timing; they highlight practical compliance steps and a one‑page deadline summary.

Why it matters

CMS revised the Medicare 60‑Day Repayment Rule (announced in 2026), changing the method for when an overpayment is "identified" and thereby altering the start of the 60‑day repayment window.

Key details

  • The change affects internal investigation timelines and when providers must report and repay overpayments — Husch Blackwell attorneys Bryan Nowicki and Andrew Brenton explain new deadlines and practical steps for compliance.
  • Husch Blackwell provides a one‑page summary of key deadlines and a detailed PDF on the updated 60‑Day Repayment Rule (video published 2026-06-18; URL: https://www.youtube.com/watch?v=BT2l6Hwt7kc).
Source evidence

CMS revised the Medicare 60-Day Repayment Rule, changing how overpayments are identified. In this episode, Husch Blackwell’s Bryan Nowicki (https://www.huschblackwell.com/professionals/bryan-nowicki) and Andrew Brenton (https://www.huschblackwell.com/professionals/andrew-brenton) analyze this change and how it affects the time frames applicable to internal investigations and repayment obligations. They also introduce a handy one-page summary of key deadlines.

Additional resources:

60-Day Repayment Rule (https://hbfiles.blob.core.windows.net/webfiles/60-Day%20Repayment%20Rule.pdf)

Channel: Husch Blackwell
Published: 2026-06-18
Video URL: https://www.youtube.com/watch?v=BT2l6Hwt7kc