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Series: Selected Inpatient and Outpatient Billing Requirements

Announced on  | Last Modified on  | Series Number: SRS-A-25-012
Status
Active
Agency
Centers for Medicare and Medicaid Services

OBJECTIVE

This review is part of a series of hospital compliance reviews that focus on hospitals with claims that may be at risk for overpayments. Prior OIG reviews and investigations have identified areas at risk for noncompliance with Medicare billing requirements. We will review Medicare payments to acute care hospitals to determine hospitals' compliance with selected billing requirements and recommend recovery of overpayments. Our review will focus on those hospitals with claims that may be at risk for overpayments.

There are 13 projects in this series.

Project titles will remain unpublished until projects are complete and reports are posted.

ACTIVE PROJECTS IN THIS SERIES (12)

Project A-07-21-05134 • Announced on Sep 14, 2021

Project A-07-21-05133 • Announced on Nov 18, 2021

Project A-04-22-07101 • Announced on Aug 3, 2022

Project A-02-22-01022 • Announced on Aug 16, 2022

Project A-04-23-08095 • Announced on Oct 11, 2022

Project A-09-23-03001 • Announced on Oct 26, 2022

Project A-05-23-00004 • Announced on Nov 2, 2022

Project A-04-23-07104 • Announced on Dec 1, 2022

Project A-03-23-00001 • Announced on Jan 5, 2023

Project A-07-24-05148 • Announced on Jan 26, 2024

Project A-07-24-05147 • Announced on Jan 26, 2024

Project OAS-25-04-089 • Announced on Jun 12, 2025

COMPLETED PROJECTS IN THIS SERIES (1)

Sarasota Memorial Hospital

Project A-04-23-08098 • Completed on February 25, 2026

TIMELINE

  • September 14, 2021
    Series Number SRS-A-25-012 Assigned
  • September 14, 2021
    Project Announced

    Project A-07-21-05134

  • November 18, 2021
    Project Announced

    Project A-07-21-05133

  • August 3, 2022
    Project Announced

    Project A-04-22-07101

  • August 16, 2022
    Project Announced

    Project A-02-22-01022

  • October 11, 2022
    Project Announced

    Project A-04-23-08095

  • October 26, 2022
    Project Announced

    Project A-09-23-03001

  • November 2, 2022
    Project Announced

    Project A-05-23-00004

  • December 1, 2022
    Project Announced

    Project A-04-23-07104

  • January 5, 2023
    Project Announced

    Project A-03-23-00001

  • February 13, 2023
    Project Announced

    Sarasota Memorial Hospital - A-04-23-08098

  • January 26, 2024
    Projects Announced

    Project A-07-24-05147

  • Project A-07-24-05148

  • June 12, 2025
    Project Announced

    Project OAS-25-04-089

  • February 25, 2026
    Project Complete - A-04-23-08098

    Sarasota Memorial Hospital complete. This audit resulted in 3 recommendations.

  • Today
    12 Projects In-Progress
  • Est FY2026
    Estimated Fiscal Year for Series Completion

1 REPORT PUBLISHED

Sarasota Memorial Hospital Received At Least $12.1 Million in Medicare Overpayments (A-04-23-08098)
  • 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.

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
Work Plan Type
Office of Audit Services
HHS Agencies
Centers for Medicare and Medicaid Services
Issue Areas
Hospitals
Target Groups
Elderly
Financial Groups
Medicare A