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Audit of Medicare Payments for Emergency Department Services Provided in Nonemergency Department Sites of Service

Announced on  | Last Modified on  | Project Number: A-07-23-05139

OBJECTIVE

An emergency department is defined as an organized hospital-based facility for the provision of unscheduled or episodic services to patients who present for immediate medical attention. Certain Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes should be used only if a Medicare enrollee is seen in the emergency department and the services described by the codes' definitions are provided. Medicare reimburses providers based on the patient's documented service needs at the time of the visit and based on the site of service. This audit will determine whether Medicare appropriately paid hospitals and physicians for emergency department services provided in nonemergency department sites of service.

TIMELINE

  • September 11, 2023
    Announced
  • March 9, 2026
    Complete

    Audit of Medicare Payments for Emergency Department Services Provided in Nonemergency Department Sites of Service complete. This audit resulted in 5 recommendations.

REPORT PUBLISHED

26-A-07-051.01 to CMS - Open Unimplemented
Update expected on 09/08/2026
We recommend that CMS direct the Medicare contractors to recover the $922,524 in improper payments made to physicians for claims in which emergency department procedure codes were billed with nonemergency place of service codes.

26-A-07-051.02 to CMS - Open Unimplemented
Update expected on 09/08/2026
We recommend that CMS direct the Medicare contractors to assess the potentially improper payments made to hospitals identified in this report for: non-CAHs totaling $9,553,078, to determine the allowability of those payments and recoup any improper payments, CAHs totaling $4,656,827, to determine the allowability of those payments and adjust any Medicare reimbursement, and deductibles that the Medicare contractors determine to have been improperly collected from enrollees, and direct the relevant hospitals to reimburse enrollees for the deductibles that the hospitals should not have charged.

26-A-07-051.03 to CMS - Open Unimplemented
Update expected on 09/08/2026
We recommend that CMS direct the Medicare contractors to implement or refine claims processing controls, such as system edits, to identify and prevent improper payments of claims for emergency department services billed with nonemergency place of service codes.

26-A-07-051.04 to CMS - Open Unimplemented
Update expected on 09/08/2026
We recommend that CMS specify in the Manual that hospitals are required to use emergency revenue center codes when billing Medicare claims containing emergency department procedure codes.

26-A-07-051.05 to CMS - Open Unimplemented
Update expected on 09/08/2026
We recommend that CMS direct the Medicare contractors to review claims submitted by providers after our audit period to identify instances when Medicare paid providers for claims in which emergency department procedure codes were billed with nonemergency place of service or revenue center codes, and recover any improper payments identified.

View in Recommendation Tracker

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