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Review of Medicare Trauma Centers

Announced on  | Last Modified on  | Project Number: A-01-23-00500
Status
Completed
Agency
Centers for Medicare and Medicaid Services

OBJECTIVE

There have been concerns about trauma centers improperly billing for trauma team activation that is not medically necessary. In addition, we found some providers have received trauma team activation payments without proper designation or verification. Currently, CMS does not track which providers are designated or verified as trauma centers. We will determine the amount of Medicare overpayments and Medicare charges that affect future hospital payments, and we will identify providers that are not trauma centers or that billed for medically unnecessary trauma team activations.

TIMELINE

REPORT PUBLISHED

Hospitals Charged CMS for Trauma Team Activations That Did Not Comply With Federal Requirements (A-01-23-00500)
  • CMS made Medicare payments to trauma centers for trauma team activations that did not comply with Federal requirements. Specifically, 107 of 125 sampled claims with trauma team activations did not meet Medicare requirements—100 sampled claims had unallowable trauma team activation charges that totaled $728,468, and 7 sampled claims had coding errors that did not have any impact on payment or charges associated with the trauma team activation.
  • We estimated that approximately 77 percent of all claims submitted to Medicare with trauma team activations did not comply with Federal requirements. Additionally, we estimated that hospitals also billed approximately $2.4 billion in unallowable charges for trauma team activations that did not meet Medicare requirements from January 1, 2020, through June 30, 2022.

25-A-01-123.01 to CMS - Open Unimplemented
Update expected on 03/22/2026
We recommend that the Centers for Medicare & Medicaid Services take the necessary steps to address the estimated $2.4 billion in unallowable trauma team activation charges reported on hospitals' cost reports and the resulting incorrect outlier payments to improve the accuracy of data used to establish future PPS payment rates.

25-A-01-123.02 to CMS - Open Unimplemented
Update expected on 03/22/2026
We recommend that the Centers for Medicare & Medicaid Services work with the MACs to identify similar instances of noncompliance that occurred after our audit period to determine and address the impact to the Federal Government related to claims for trauma team activation that did not comply with Federal requirements.

25-A-01-123.03 to CMS - Open Unimplemented
Update expected on 03/22/2026
We recommend that the Centers for Medicare & Medicaid Services revise CMS guidance to explain when trauma team activation is reasonable and necessary (e.g., by incorporating ACS trauma center requirements and, if necessary, providing specific examples).

25-A-01-123.04 to CMS - Open Unimplemented
Update expected on 03/22/2026
We recommend that the Centers for Medicare & Medicaid Services provide more frequent education to hospitals on CMS requirements for submitting claims with trauma team activation.

View in Recommendation Tracker
Work Plan Type
Office of Audit Services
HHS Agencies
Centers for Medicare and Medicaid Services
Issue Areas
Financial Stewardship Hospitals
Target Groups
-
Financial Groups
Medicare A Medicare B