Payments for Ambulatory Surgical Center Services Provided to Beneficiaries in Skilled Nursing Facility Stays Covered Under Medicare Part A in Calendar Years 2006 through 2008

Based on our sample results, we estimated that Medicare contractors made at least $6.6 million in overpayments to ambulatory surgical centers (ASC) for services provided to beneficiaries during Part A skilled nursing facility (SNF) stays in calendar years 2006 through 2008. All 100 services that we reviewed, totaling $103,000, were incorrectly billed to Medicare Part B even though they were included in the SNFs' Part A payments. As a result, Medicare paid twice for these services: once to the SNF under the Part A prospective payment system and again to the ASC under Part B.

We recommended that the Centers for Medicare & Medicaid Services (CMS) instruct its Medicare contractors to: (1) recover the $103,000 in overpayments for the 100 incorrectly billed services that we identified; (2) review the 20,806 services that we did not review and recover overpayments estimated to total at least $6.5 million; and (3) provide guidance to ASCs on consolidated billing requirements and the need for timely and accurate communication between ASCs and SNFs regarding beneficiaries' Medicare Part A status. We also recommended that CMS establish an edit in the Common Working File to prevent Part B payments for ASC services that are subject to consolidated billing.