"CMS adopted an expansive and clearly erroneous standard ...

... for when an overpayment, as defined in [the agency's final rule on the return of Medicare Advantage overpayments], has purportedly been 'identified' by a Medicare Advantage plan. CMS not only refused to narrow its overly broad proposed definition, it made it broader."

— Excerpted from a lawsuit against CMS filed by UnitedHealth Group on Jan. 29.