Review of Emergency Health Services at Florida Hospital Furnished to Undocumented Aliens Covered by Section 1011 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003

Of the 31 sampled claims submitted by Florida Hospital for services provided under section 1011 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) for the period May 10 through September 30, 2005, 7 claims totaling $23,000 met section 1011 requirements and were eligible for section 1011 program reimbursement. The 24 remaining claims totaling $93,000 were either partially or completely unallowable for section 1011 program reimbursement. As a result, Florida Hospital received $67,000 in unallowable payments. Section 1011 of the MMA provided $250 million per year for fiscal years 2005 through 2008 for payments to eligible providers for emergency health services provided to undocumented aliens and other specified aliens pursuant to Emergency Medical Treatment and Labor Act requirements.

We recommended that Florida Hospital (1) refund to its program contractor $67,000 for services that did not meet section 1011 reimbursement requirements; (2) review the 51 remaining claims for our audit period, totaling $82,000, and claims for subsequent periods and submit adjustments for any claims that did not meet section 1011 reimbursement requirements; (3) follow its existing policies and procedures to ensure that future section 1011 program claims meet section 1011 reimbursement requirements; and (4) develop and implement procedures to ensure that section 1011 program claims are for covered services up to the point of stabilization rather than through the patients' entire hospital stays.

In written comments on our draft report, Florida Hospital did not directly comment on the first three of our four recommendations. Regarding the fourth recommendation, the hospital said that it had modified its internal processes and would ensure that all future claims are not billed past the point of stabilization. Nothing in Florida Hospital's comments caused us to revise our findings or recommendations.