Hospital Billing Requirements Review for Overpayment Risk

HHS OIG Work Plan

Published September 14th, 2021

Detected March 13th, 2026

Summary

The Centers for Medicare and Medicaid Services (CMS) announced a review series focused on hospital billing requirements to identify overpayment risks. A completed project for Sarasota Memorial Hospital identified at least $12.1 million in Medicare overpayments due to non-compliance with billing requirements.

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What changed

The Centers for Medicare and Medicaid Services (CMS), through its Office of Inspector General (OIG), has initiated a series of reviews examining hospital compliance with selected Medicare billing requirements. This initiative aims to identify hospitals with claims at risk for overpayments, building on prior OIG findings. The Sarasota Memorial Hospital project, completed on February 25, 2026, identified that the hospital received at least $12.1 million in net Medicare overpayments between January 1, 2020, and December 31, 2021, due to failures in following its own policies for accurate Medicare claim billing.

This ongoing series of reviews signals a heightened focus on hospital billing integrity and potential recovery of Medicare funds. Healthcare providers, particularly acute care hospitals, should anticipate similar reviews and ensure their billing practices strictly adhere to all Medicare requirements and internal policies. While specific deadlines for this series are not provided, the completion of the Sarasota Memorial Hospital project and the ongoing nature of the other 12 active projects indicate that compliance is a current and active concern. Non-compliance could lead to significant financial recovery actions by CMS.

What to do next

Review internal policies and procedures for Medicare billing compliance.
Assess historical Medicare claims for potential overpayments based on identified risk areas.
Ensure adherence to all selected inpatient and outpatient billing requirements.

Penalties

Estimated net overpayments of at least $12.1 million for Sarasota Memorial Hospital. Recovery of overpayments is a stated objective of the review series.

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Series: Selected Inpatient and Outpatient Billing Requirements

Announced on

09/14/2021

| Last Modified on

02/25/2026

| 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. Report Published
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.
Recommendations are updated each month and may not immediately be available for recently completed projects. 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