Under reverse FCA what action avoids liability?

Under reverse FCA what action avoids liability?

• A. Voluntarily identify, disclose, and refund overpayments.
• B. Not refund overpayments.
• C. Report to the OIG.
• D. Seek external audit.

Answer: (A)

Under the reverse FCA, liability comes from knowingly retaining an overpayment. The action that avoids liability is to act quickly and transparently by identifying the overpayment, disclosing it to the appropriate authorities, and refunding the amount. This demonstrates good faith and a commitment to correcting errors, showing that you did not intend to keep funds you weren’t entitled to and reducing the time the overpayment remains with you. While reporting to the OIG or arranging an external audit can support compliance, they don’t by themselves remove liability unless paired with timely self-disclosure and refund. The key idea is prompt recognition and remediation of an overpayment.

Under the reverse FCA, liability comes from knowingly retaining an overpayment. The action that avoids liability is to act quickly and transparently by identifying the overpayment, disclosing it to the appropriate authorities, and refunding the amount. This demonstrates good faith and a commitment to correcting errors, showing that you did not intend to keep funds you weren’t entitled to and reducing the time the overpayment remains with you. While reporting to the OIG or arranging an external audit can support compliance, they don’t by themselves remove liability unless paired with timely self-disclosure and refund. The key idea is prompt recognition and remediation of an overpayment.