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Medicare Compliance Review of Memorial University Medical Center

Memorial University Medical Center complied with Medicare billing requirements for 92 of the 131 inpatient and outpatient claims we reviewed. However, the Hospital did not fully comply with Medicare billing requirements for the remaining 39 claims, resulting in overpayments of $599,530.

On the basis of our sample results, we estimated that the Hospital received overpayments of at least $1.4 million for the audit period. During the course of the audit, the Hospital submitted some of these claims for reprocessing that we verified as correctly reprocessed. Accordingly, we have reduced the recommended refund by this amount.

We recommended that the Hospital refund the Medicare contractor $1.3 million ($1.4 million less $155,072 that had already been repaid) in estimated overpayments for the audit period for claims that it incorrectly billed; exercise reasonable diligence to identify and return any additional similar overpayments received outside of our audit period, in accordance with the 60-day rule; and strengthen controls to ensure full compliance with Medicare requirements.

The Hospital did not agree with all of our findings and recommendations. Specifically, the Hospital disagreed with 17 of the 39 claim errors that we identified as not fully complying with Medicare billing requirements. We obtained independent medical review for compliance with Inpatient Rehabilitation Facility (IRF) medical necessity requirements. The independent medical reviewers were provided with all documentation necessary to sufficiently determine medical necessity for the IRF claims, and our report reflects the results of that review. Therefore, we maintain that all of our findings and recommendations are correct.

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Download the complete report or the Report in Brief.

Office of Inspector General, U.S. Department of Health and Human Services | 330 Independence Avenue, SW, Washington, DC 20201