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Sarasota Memorial Hospital Received At Least $12.1 Million in Medicare Overpayments

Issued on  | Posted on  | Report number: A-04-23-08098

Why OIG Did This Audit

  • For calendar year 2021, Medicare paid hospitals $182 billion, which represents 46 percent of all fee-for-service payments; accordingly, it is important that hospital payments comply with requirements.
  • This audit is part of a series of audits examining hospitals with a high volume of claims previously identified as high-risk for noncompliance.
  • Sarasota Memorial Hospital (the Hospital) was selected because it submitted a substantial number of potentially high-risk claims to Medicare.

What OIG Found

  • The Hospital complied with Medicare billing requirements for 74 of the 100 inpatient and outpatient claims we reviewed. However, the Hospital did not fully comply with Medicare billing requirements for the remaining 26 claims, resulting in net overpayments of $272,364 from January 1, 2020, through December 31, 2021 (audit period).
  • On the basis of our sample results, we estimated that the Hospital received net overpayments of at least $12.1 million for the audit period.
  • These errors occurred primarily because the Hospital did not always follow its written policies and procedures to prevent the incorrect billing of Medicare claims within the selected risk areas that contained errors.

What OIG Recommends

We recommend that the Hospital refund to the Federal government the $12.1 million in estimated net overpayments, consider conducting internal audits for claims after our audit period based on the risks identified by this audit, and provide additional training regarding Medicare billing requirements. Our complete recommendations are found in the audit report.

The Hospital disagreed with most of our findings and all our recommendations.

26-A-04-049.01 to CMS - Open Unimplemented
Update expected on 08/24/2026
We recommend that the Hospital refund to the Federal government the estimated $12,199,717 in net overpayments for incorrectly billed claims, excluding amounts presumed to be unrecoverable under the Section 1870 waiver of liability provision.

26-A-04-049.02 to CMS - Open Unimplemented
Update expected on 08/24/2026
We recommend that the Hospital consider conducting one or more internal audits or investigations for claims beyond our audit period, based on the risks identified by this audit, to identify any similar overpayments and return any identified overpayments to the Medicare program.

26-A-04-049.03 to CMS - Open Unimplemented
Update expected on 08/24/2026
We recommend that the Hospital provide additional training to clinical and billing personnel on its policies and procedures related to the following: The Two-Midnight Rule; The medical necessity of inpatient and outpatient services; IRF admissions; The billing of services provided; Inpatient and outpatient coding.

View in Recommendation Tracker