MEDICARE FRAUD

Progress Made, but More 

Action Needed to Address 

Medicare Fraud, Waste, 

and Abuse

Statement of Kathleen M. King

Director, Health Care

Testimony 

Before the Subcommittee on Health, 

Committee on Ways and Means, 

House of Representatives

For Release on Delivery 

Expected at 2:00 p.m. ET

Wednesday, April 30, 2014

GAO-14-560T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-560T, a testimony 

before the Subcommittee on Health, 

Committee on Ways and Means, House of 

Representatives

April 30, 2014

MEDICARE FRAUD

Progress Made, but More Action Needed to Address 

Medicare Fraud, Waste, and Abuse

Why GAO Did This Study

GAO has designated Medicare as a 

high-risk program, in part because the 

program’s size and complexity make it 

vulnerable to fraud, waste, and abuse. 

In 2013, Medicare financed health care 

services for approximately 51 million 

individuals at a cost of about 

$604 billion. The deceptive nature of 

fraud makes its extent in the Medicare 

program difficult to measure in a 

reliable way, but it is clear that fraud 

contributes to Medicare’s fiscal 

problems. More broadly, in fiscal year 

2013, CMS estimated that improper 

payments—some of which may be 

fraudulent—were almost $50 billion.

This statement focuses on the 

progress made and important steps to 

be taken by CMS and its program 

integrity contractors to reduce fraud in 

Medicare. These contractors perform 

functions such as screening and 

enrolling providers, detecting and 

investigating potential fraud, and 

identifying improper payments and 

vulnerabilities that could lead to 

payment errors. This statement is 

based on relevant GAO products and 

recommendations issued from 2004 

through 2014 using a variety of 

methodologies. In April 2014, GAO 

also received updated information from 

CMS on its actions related to the laws, 

regulations, and guidance discussed in 

this statement. Additionally, GAO 

updated information by examining 

public documents and relevant policies 

and procedures.

What GAO Found

The Centers for Medicare & Medicaid Services (CMS)—the agency within the 

Department of Health and Human Services (HHS) that oversees Medicare—has 

made progress in implementing several key strategies GAO identified in prior 

work as helpful in protecting Medicare from fraud; however, important actions 

that could help CMS and its program integrity contractors combat fraud remain 

incomplete. 

Provider Enrollment: The Patient Protection and Affordable Care Act (PPACA) 

authorized, and CMS has implemented, actions to strengthen provider enrollment 

that address past weaknesses identified by GAO and HHS’s Office of Inspector 

General. For example, CMS has hired contractors to determine whether

providers and suppliers have valid licenses and are at legitimate locations. CMS 

also recently contracted for fingerprint-based criminal history checks for high-risk 

providers and suppliers. CMS could further strengthen provider enrollment by 

issuing a rule to require additional provider and supplier disclosures of 

information and establishing core elements for provider and supplier compliance 

programs, as authorized by PPACA. 

Prepayment and Postpayment Claims Review: Medicare uses prepayment 

review to deny claims that should not be paid and postpayment review to recover 

improperly paid claims. GAO has found that increased use of prepayment edits 

could help prevent improper Medicare payments. For example, prior GAO work 

identified millions of dollars of payments inconsistent with selected coverage and 

payment policies and therefore improper. Postpayment reviews are also critical 

to identifying and recouping payments. GAO recommended better oversight of 

both the information systems analysts use to identify claims for postpayment 

review, in a 2011 report, and the contractors responsible for these reviews, in a 

2013 report. CMS has addressed some of these recommendations.

Addressing Identified Vulnerabilities: Having mechanisms in place to resolve 

vulnerabilities that could lead to improper payments is critical to effective 

program management and could help address fraud. However, GAO work has 

shown weaknesses in CMS’s processes to address such vulnerabilities, placing 

the Medicare program and its beneficiaries at risk. For example, GAO has made 

multiple recommendations to CMS to remove Social Security numbers from 

beneficiaries’ Medicare cards to help prevent identity theft, and, while HHS

agreed with these recommendations, the department also reported that CMS

could not proceed with the changes for a variety of reasons, including funding 

limitations. Thus, to date, CMS has not taken action on these recommendations.

GAO has work underway addressing these key strategies, including assessing 

the potential use of electronic-card technologies to help reduce Medicare fraud. 

GAO is also examining the extent to which CMS’s information system can 

prevent and detect the continued enrollment of ineligible or potentially fraudulent 

providers in Medicare. Additionally, GAO is studying CMS’s oversight of program 

integrity efforts for prescription drugs and is examining CMS’s oversight of some 

of the contractors that conduct reviews of claims after payment. These studies 

are focused on additional actions for CMS that could help the agency more 

systematically reduce potential fraud in the Medicare program.

View GAO-14-560T. For more information, 

contact Kathleen M. King at (202) 512-7114 or 

kingk@gao.gov.
 

Page 1 GAO-14-560T Medicare Fraud

Chairman Brady, Ranking Member McDermott, and Members of the 

Subcommittee:

I am pleased to be here today to discuss our work examining fraud in the 

Medicare program.1 We have designated Medicare as a high-risk 

program since 1990, in part because we found the program’s size and 

complexity make it vulnerable to fraud, waste, and abuse.2 Although there 

have been convictions for multimillion-dollar schemes that defrauded the 

Medicare program, the extent of the problem is unknown.3

In 2013, Medicare financed health care services for approximately 

51 million individuals at a cost of about $604 billion, and reported some of 

the largest estimates of improper payments among federal programs—

payments that either were made in an incorrect amount or should not 

There are no 

reliable estimates of the extent of fraud in the Medicare program or for the 

health care industry as a whole. By its very nature, fraud is difficult to 

detect, as those involved are engaged in intentional deception. For 

example, a provider submitting a fraudulent claim may include false 

documentation to substantiate a service not provided, and thus the claim 

may appear valid on its face. Fraud may also involve payments made to 

beneficiaries to obtain their Medicare number for fraudulent billing 

purposes. Although the full extent of the problem is unknown, it is clear 

that, as one of the largest programs in the federal government, the 

Medicare program is vulnerable to fraud, contributing to its fiscal 

problems.

 

1

Medicare is the federally financed health insurance program for persons age 65 or over, 

certain individuals with disabilities, and individuals with end-stage renal disease.

2

In 1990, we began to report on government operations that we identified as “high risk” for 

serious weaknesses in areas that involve substantial resources and provide critical 

services to the public. Medicare has been included among such programs since 1990. 

See GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: February 2013).

3

Fraud involves an intentional act or representation to deceive with the knowledge that the 

action or representation could result in gain.
 

Page 2 GAO-14-560T Medicare Fraud

have been made at all.4 The Centers for Medicare & Medicaid Services 

(CMS), the agency within the Department of Health and Human Services 

(HHS) that oversees Medicare, has estimated that improper payments in 

the Medicare program were almost $50 billion in fiscal year 2013, about 

$5 billion higher than in 2012.5

Since its inception, Medicare has been administered largely by 

contractors with federal oversight and these contractors have a 

responsibility to help ensure Medicare program integrity.6 CMS must 

oversee their efforts to help ensure proper payments and address the 

program’s many vulnerabilities, which include service- or system-specific 

weaknesses that can lead to payment errors, including those due to 

fraud.7

 

4

Improper payments may be a result of fraud, waste, or abuse. They are any payments 

that should not have been made or that were made in an incorrect amount (including 

overpayments and underpayments) under statutory, contractual, administrative, or other 

legally applicable requirements. This definition includes any payment to an ineligible 

recipient, any payment for an ineligible good or service, any duplicate payment, any 

payment for a good or service not received (except where authorized by law), and any 

payment that does not account for credit for applicable discounts. Improper Payments 

Elimination and Recovery Act of 2010, Pub. L. No. 111-204, § 2(e), 124 Stat. 2224, 2227 

(codified at 31 U.S.C. § 3321 note). Waste includes inaccurate payments for services, 

such as unintentional duplicate payments. Abuse represents actions inconsistent with 

acceptable business or medical practices.

If CMS suspects that providers or suppliers are billing fraudulently, 

it can take action through its contractors, including suspending claims 

5

A list of abbreviations used in this statement is provided in appendix I.

6

The Medicare program consists of four parts: A, B, C, and D. Medicare Parts A and B are 

known as Medicare fee-for-service (FFS). Medicare Part A covers hospital and other 

inpatient stays. Medicare Part B is optional, and covers hospital outpatient, physician, and 

other services. Medicare beneficiaries have the option of obtaining coverage for Medicare 

services from private health plans that participate in Medicare Advantage—Medicare’s 

managed care program—also known as Part C. All Medicare beneficiaries may purchase 

coverage for outpatient prescription drugs under Part D, either as a stand-alone benefit or 

as part of a Medicare Advantage plan. Contractors are responsible for administering 

Medicare FFS claims and conducting activities to reduce improper payments. 

7

CMS defines vulnerabilities to the Medicare program as issues that can lead to fraud, 

waste, or abuse, which can either be specific, such as providers receiving multiple 

payments as a result of incorrect coding for a service, or general and programwide, such 

as weaknesses in online application processes. An example of a vulnerability that leads to 

improper payments is providers billing for more than one blood transfusion in a hospital 

outpatient setting for a Medicare beneficiary in a day, which Medicare policy does not 

allow.
 

Page 3 GAO-14-560T Medicare Fraud

payment, revoking billing privileges, or referring cases to law enforcement 

for investigation.8

My statement today focuses on the progress made and important steps to 

be taken by CMS to reduce fraud in Medicare. It is primarily based on our 

Medicare program integrity products issued and recommendations made 

from April 2004 through March 2014, as well as selected updates on CMS 

activities,

9 and will focus on progress related to three key strategies we 

have identified as important to reducing fraud, waste, and abuse, and 

ultimately improper payments:10

• strengthening provider enrollment standards and procedures,

• improving prepayment and postpayment review of claims, and

• addressing identified vulnerabilities.

We received updated information from CMS in April 2014 on its actions 

related to the laws, regulations, and guidance that we discuss in this 

statement. We also updated information by examining public documents 

and relevant policies and procedures. Our work for this statement and the 

products on which it was based was conducted in accordance with 

generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on 

our audit objectives.

 

8

In this testimony, the term provider includes entities such as hospitals or physicians, and 

supplier means an entity that supplies Medicare beneficiaries with durable medical 

equipment, prosthetics, orthotics, and supplies (DMEPOS) such as walkers and 

wheelchairs.

9

The products listed at the end of this statement contain detailed information on the 

various methodologies used in our work.

10See GAO, Program Integrity: Further Action Needed to Address Vulnerabilities in 

Medicaid and Medicare Programs, GAO-12-803T (Washington, D.C.: June 7, 2012). 
 

Page 4 GAO-14-560T Medicare Fraud

Since 1996, Congress has taken important steps to increase Medicare 

program integrity funding and oversight, including the establishment of 

the Medicare Integrity Program. Table 1 summarizes several key 

congressional actions.

Table 1: Key Congressional Actions to Increase Medicare Program Integrity Funding and Oversight

Year Congressional action Statute 

1996 Created the Medicare Integrity Program and established dedicated funding for activities 

to address fraud, waste, and abuse in federal health care programs, including Medicarea Health Insurance Portability and 

Accountability Act of 1996b

2003 Directed CMS to conduct a 3-year demonstration project on the use of recovery audit 

contractors (RAC) for identifying Medicare underpayments and recouping overpayments

Medicare Prescription Drug, 

Improvement, and Modernization 

Act of 2003c

2006 Required CMS to implement a national RAC program by January 1, 2010. Tax Relief and Health Care Act of 

2006d

2010 Provided additional funding for program integrity activities and, among other things:

• Established new provider enrollment requirements

• Required CMS to extend the Medicare RACs to Parts C and D of the Medicare 

program

• Required CMS to develop core elements for provider compliance programs

• Authorized surety bond requirements for certain Medicare suppliers and providerse

Patient Protection and Affordable 

Care Act (PPACA)f

2010 Required Medicare fee-for-service to begin using predictive analytics to identify and 

prevent fraudg Small Business Jobs Act of 2010h

Source: GAO analysis.

a

The fund is known as the Health Care Fraud and Abuse Control account.

b

Pub. L. No. 104-191, §§ 201(b)-202, 110 Stat. 1936, 1993-98 (codified at 42 U.S. C. §§ 1395i(k), 

1395ddd).

c

Pub. L. No. 108-173, § 306, 117 Stat. 2066, 2256-57.

d

Pub. L. No. 109-432, div B., title III, § 302, 120 Stat. 2922, 2991-92 (codified at 42 U.S.C. § 1395 

ddd(h)).

e

A surety bond is a three-party agreement in which a company, known as a surety, agrees to 

compensate the bondholder if the bond purchaser fails to keep a specified promise.

f

Pub. L. No. 111-148, 124 Stat. 119 (2010), as amended by the Health Care and Education 

Reconciliation Act of 2010, Pub. L. No. 111-152, 124 Stat. 1029

g

Predictive analytics include the use of algorithms and models to analyze claims before payment is 

made in order to identify unusual or suspicious patterns or abnormalities in provider networks, claims 

billing patterns, and beneficiary utilization.

h

Pub. L. No. 111-240, § 4241, 124 Stat. 2504, 2599.

Background
 

Page 5 GAO-14-560T Medicare Fraud

CMS has made progress in strengthening provider enrollment provisions, 

but needs to do more to identify and prevent potentially fraudulent 

providers from participating in Medicare. Additional improvements to 

prepayment and postpayment claims review would help prevent and 

recover improper payments. Addressing payment vulnerabilities already 

identified could further help prevent or reduce fraud.

PPACA authorized and CMS has implemented new provider enrollment 

procedures that address past weaknesses identified by GAO and HHS’s 

Office of Inspector General (OIG) that allowed entities intent on 

committing fraud to enroll in Medicare. CMS has also implemented other 

measures intended to improve existing procedures. Specifically, to 

strengthen the existing screening activities conducted by CMS 

contractors, the agency added screenings of categories of provider 

enrollment applications by risk level, contracted with new national 

enrollment screening and site visit contractors, and began imposing 

moratoria on new enrollment of certain types of providers.

• Screening Provider Enrollment Applications by Risk Level: CMS and 

OIG issued a final rule in February 2011 to implement many of the 

new screening procedures required by PPACA.11 CMS designated 

three levels of risk—high, moderate, and limited—with different 

screening procedures for categories of Medicare providers at each 

level. Providers in the high-risk level are subject to the most rigorous 

screening.12

 

11Medicare, Medicaid, and Children’s Health Insurance Programs; Additional Screening 

Requirements, Application Fees, Temporary Enrollment Moratoria, Payment Suspensions 

and Compliance Plans for Providers and Suppliers, 76 Fed. Reg. 5862 (Feb. 2, 2011). In 

discussing the final rule, CMS noted that Medicare had already employed a number of the 

screening practices described in PPACA to determine whether a provider is in compliance 

with federal and state requirements to enroll or to maintain enrollment in the Medicare 

program.

Based in part on our work and that of OIG, CMS 

designated newly enrolling home health agencies and suppliers of 

durable medical equipment, prosthetics, orthotics, and supplies 

(DMEPOS) as high risk, and designated other providers as lower risk 

levels. Providers at all risk levels are screened to verify that they meet 

12PPACA specified that the enhanced screening procedures apply to new providers and 

suppliers beginning 1 year after the date of enactment (March 23, 2010) and to currently 

enrolled providers and suppliers 2 years after that date.

CMS Has Taken 

Action to Improve 

Medicare Program 

Integrity, but More 

Can Be Done

CMS Has Strengthened 

Provider Enrollment 

Provisions since PPACA, 

but Further Actions 

Needed to Help Ensure 

Potentially Fraudulent 

Providers Do Not 

Participate in Medicare
 

Page 6 GAO-14-560T Medicare Fraud

specific requirements established by Medicare, such as having 

current licenses or accreditation and valid Social Security numbers.13

High- and moderate-risk providers are also subject to unannounced 

site visits. Further, depending on the risks presented, PPACA 

authorizes CMS to require fingerprint-based criminal history checks. 

Last month, CMS awarded a contract that will enable the agency to 

access Federal Bureau of Investigation information to help conduct 

those checks of high-risk providers and suppliers. PPACA also 

authorizes the posting of surety bonds for certain providers.14

CMS has indicated that the agency will continue to review the criteria

for its screening levels and will publish changes if the agency decides 

to update the assignment of screening levels for categories of 

Medicare providers. Doing so could become important because the 

Department of Justice (DOJ) and HHS reported multiple convictions, 

judgments, settlements, or exclusions against types of providers not 

currently at the high-risk level, including community mental health 

centers and ambulance providers.15 CMS’s implementation of 

accreditation for DMEPOS suppliers, and of a competitive bidding 

program, including in geographic areas thought to have high fraud 

rates, may be helping to reduce the risk of DMEPOS fraud.16

 

13Screening may include verification of the following: Social Security number; National 

Provider Identifier (NPI); National Practitioner Databank licensure; whether the provider 

has been excluded from federal health care programs by OIG; taxpayer identification 

number; and death of an individual practitioner, owner, authorized official, delegated 

official, or supervising physician.

 While 

continued vigilance of DMEPOS suppliers is warranted, other types of 

providers may become more problematic in the future. Specifically, in 

September 2012, we found that a range of providers have been the 

14A surety bond is a three-party agreement in which a company, known as a surety, 

agrees to compensate the bondholder if the bond purchaser fails to keep a specified 

promise.

15Department of Health and Human Services and the Department of Justice, Health Care 

Fraud and Abuse Control Program Annual Report for Fiscal Year 2013 (Washington, D.C.: 

February 2014).

16Competitive bidding is a process in which suppliers of medical equipment and supplies 

compete for the right to provide their products on the basis of established criteria, such as 

quality and price. See GAO, Medicare: Second Year Update for CMS’s Durable Medical 

Equipment Competitive Bidding Program Round 1 Rebid, GAO-14-156 (Washington, D.C.: 

Mar. 7, 2014).
 

Page 7 GAO-14-560T Medicare Fraud

subjects of fraud investigations.17 According to 2010 data from OIG 

and DOJ, over 10,000 providers that serve Medicare, Medicaid, and 

Children’s Health Insurance Program beneficiaries were involved in 

fraud investigations, including not only home health agencies and 

DMEPOS suppliers, but also physicians, hospitals, and pharmacies.18

• National Enrollment Screening and Site Visit Contractors: CMS 

contracted with two new types of entities at the end of 2011 to 

assume centralized responsibility for two functions that had been the 

responsibility of multiple contractors. One of the new contractors is 

conducting automated screenings to check that existing and newly 

enrolling providers and suppliers have valid licensure, accreditation, 

and a National Provider Identifier (NPI), and are not on the OIG list of 

providers and suppliers excluded from participating in federal health 

care programs. The second contractor conducts site visits of providers 

to determine whether sites are legitimate and the providers meet 

certain Medicare standards.

In addition, the provider type constituting the largest percentage of 

subjects in criminal health care fraud investigations was medical 

facilities—including medical centers, clinics, or practices—which 

constituted almost a quarter of subjects in such investigations. 

DMEPOS suppliers make up a little over 16 percent of subjects.

19 A CMS official reported that, since the 

implementation of the PPACA screening requirements, the agency 

had revoked over 17,000 suspect providers’ ability to bill the Medicare 

program.20

 

17GAO, Health Care Fraud: Types of Providers Involved in Medicare, Medicaid, and the 

Children’s Health Insurance Program Cases, GAO-12-820 (Washington, D.C.: Sept. 7, 

2012).

18Medicaid is the federal-state program that covers acute health care, long-term care, and 

other services for certain low-income people. It is also one of the largest components of 

state budgets. Children’s Health Insurance Program is the joint federal-state program that 

provides health coverage to children whose families have incomes that are low, but not 

low enough to qualify for Medicaid.

19Site visits for DMEPOS suppliers are to continue to be conducted by the contractor 

responsible for their enrollment. In addition, CMS at times exercises its authority to 

conduct a site visit or request its contractors to conduct a site visit for any Medicare 

provider or supplier.

20S. Agrawal, M.D., Deputy Administrator and Director, Center for Program Integrity, 

Centers for Medicare & Medicaid Services, Preventing Medicare Fraud: How Can We 

Best Protect Seniors and Taxpayers?, testimony before the Senate Special Aging 

Committee, Mar. 26, 2014. 
 

Page 8 GAO-14-560T Medicare Fraud

• Moratoria on Enrollment of New Providers and Suppliers in Certain 

Areas: CMS suspended enrollment of new home health providers and 

ambulance suppliers in certain fraud “hot spots” and other geographic 

areas. In July 2013, CMS first exercised its authority granted by 

PPACA to establish temporary moratoria on enrolling new home 

health agencies in Chicago and Miami, and new ambulance suppliers 

in Houston.21

We are currently examining the ability of CMS’s provider enrollment 

system to prevent and detect the continued enrollment of ineligible or 

potentially fraudulent providers in Medicare. Specifically, we are 

assessing the process used to enroll and verify the eligibility of Medicare 

providers in Medicare’s Provider Enrollment, Chain, and Ownership 

System (PECOS) and the extent to which CMS’s controls are designed to 

prevent and detect the continued enrollment of ineligible or potentially 

fraudulent providers in PECOS.

In January 2014, CMS extended its first moratoria and 

added enrollment moratoria for new home health agency providers in 

Fort Lauderdale, Detroit, Dallas, and Houston, and new ground 

ambulance suppliers in Philadelphia. These moratoria are scheduled 

to be in effect until July 2014, unless CMS extends or lifts them. CMS 

officials cited areas of potential fraud risk, such as a disproportionate 

number of providers and suppliers relative to beneficiaries and 

extremely high utilization as rationales for suspending new 

enrollments of home health providers or ground ambulance suppliers 

in these areas.

Although CMS has taken many needed actions, we and OIG have found 

that CMS has not fully implemented other enrollment screening actions 

authorized by PPACA.22

 

21Under the moratoria, existing providers and suppliers can continue to deliver and bill for 

services, but no new provider and supplier applications will be approved in these areas. 

CMS re-evaluates the need for such moratoria every 6 months.

These actions could help further reduce the 

enrollment of providers and suppliers intent on defrauding the Medicare 

program. They include issuing a rule to implement surety bonds for 

certain providers, issuing a rule on provider and supplier disclosure 

requirements, and establishing the core elements for provider and 

supplier compliance programs.

22GAO, Medicare Program Integrity: CMS Continues Efforts to Strengthen the Screening 

of Providers and Suppliers, GAO-12-351 (Washington, D.C.: Apr. 10, 2012).
 

Page 9 GAO-14-560T Medicare Fraud

• Surety Bonds: PPACA authorized CMS to require a surety bond for 

certain types of at-risk providers and suppliers. Surety bonds may 

serve as a source for recoupment of erroneous payments. DMEPOS 

suppliers are currently required to post a surety bond at the time of 

enrollment.23

• Providers and Suppliers Disclosure: CMS has not yet scheduled a 

proposed rule for publication for increased disclosures of prior actions 

taken against providers and suppliers enrolling or revalidating 

enrollment in Medicare, as authorized by PPACA, such as whether 

the provider or supplier has been subject to a payment suspension 

from a federal health care program.

CMS reported in April 2014 that it had not scheduled for 

publication a proposed rule to implement the PPACA surety bond 

requirement for other types of at-risk providers and suppliers—such 

as home health agencies and independent diagnostic testing facilities. 

In light of the moratoria that CMS has placed on enrollment of home 

health agencies in fraud “hot spots,” implementation of this rule could 

help the agency address potential concerns for these at-risk providers 

across the Medicare program.

24

• Compliance Program: CMS has not established the core elements of 

compliance programs for providers and suppliers, as required by 

PPACA. We previously reported that agency officials indicated that 

they had sought public comments on the core elements, which they 

were considering, and were also studying criteria found in OIG model 

Agency officials had indicated

that developing the additional disclosure requirements has been 

complicated by provider and supplier concerns about what types of 

information will be collected, what CMS will do with it, and how the 

privacy and security of this information will be maintained.

 

2342 U.S.C. § 1395m(a)(16)(B). A DMEPOS surety bond is a bond issued by an entity 

guaranteeing that a DMEPOS supplier will fulfill its obligation to Medicare. If the obligation 

is not met, the surety bond is paid to Medicare. Medicare Program; Surety Bond 

Requirement for Suppliers of Durable Medical Equipment, Prosthetics, Orthotics, and 

Supplies (DMEPOS), 74 Fed. Reg. 166 (Jan. 2, 2009).

24At the time of initial enrollment or revalidation of enrollment, PPACA requires providers 

and suppliers to disclose, in a form and manner and at such time as determined by the 

Secretary, any current or previous affiliation with another provider or supplier that has 

uncollected debt; has been or is subject to a payment suspension under a federal health 

care program; has been excluded from participation under Medicare, Medicaid, or State 

Children’s Health Insurance Program; or has had its billing privileges denied or revoked. 

Pub. L. No. 111-148, § 6401(a), 124 Stat. 119, 750 (2010).
 

Page 10 GAO-14-560T Medicare Fraud

plans for possible inclusion.25 As of April 2014, CMS reported that it 

had not yet scheduled a proposed rule for publication. 

Medicare uses prepayment review to deny claims that should not be paid 

and postpayment review to recover improperly paid claims. As claims go 

through Medicare’s electronic claims payment systems, they are 

subjected to prepayment controls called “edits,” most of which are fully 

automated; if a claim does not meet the criteria of the edit, it is 

automatically denied.26

Increased use of prepayment edits could help prevent improper Medicare 

payments. Our prior work found that, while use of prepayment edits saved 

Medicare at least $1.76 billion in fiscal year 2010, the savings could have 

been greater had prepayment edits been used more widely.

Other prepayment edits are manual; they flag a 

claim for individual review by trained staff who determine whether it 

should be paid. Due to the volume of claims, CMS has reported that less 

than 1 percent of Medicare claims are subject to manual medical record 

review by trained personnel.

27

 

25A compliance program is an internal set of policies, processes, and procedures that a 

provider organization implements to help it act ethically and lawfully. In this context, a 

compliance program is intended to help provider and supplier organizations prevent and 

detect violations of Medicare laws and regulations. OIG has developed a series of 

voluntary compliance program guidance documents directed at various segments of the 

health care industry, such as hospitals, nursing homes, third-party billers, and durable 

medical equipment suppliers, to encourage the development and use of internal controls 

to monitor adherence to applicable statutes, regulations, and program requirements.

Based on 

an analysis of a limited number of national policies and local coverage 

determinations (LCD), we identified $14.7 million in payments in fiscal 

year 2010 that appeared to be inconsistent with four national policies and 

26Edits are instructions programmed in the systems to prevent payment of incomplete or 

incorrect claims. Some edits use provider enrollment information, while others use 

information on coverage or payment policies, to determine whether claims should be paid.

27See GAO, Medicare Program Integrity: Greater Prepayment Control Efforts Could 

Increase Savings and Better Ensure Proper Payment, GAO-13-102 (Washington, D.C.: 

Nov. 13, 2012). 

Additional Improvements 

to Prepayment and 

Postpayment Claims 

Review May Better Identify 

or Recover Improper 

Payments
 

Page 11 GAO-14-560T Medicare Fraud

therefore improper.28 We also found more than $100 million in payments 

that were inconsistent with three selected LCDs that could have been 

identified using automated edits. Thus we concluded that more 

widespread implementation of effective automated edits developed by 

individual Medicare administrative contractors (MAC) in other MAC 

jurisdictions could also result in savings to Medicare. CMS has taken 

steps to improve the development of other types of prepayment edits that 

are implemented nationwide, as we recommended. For example, the 

agency has centralized the development and implementation of 

automated edits based on a type of national policy called national 

coverage determinations.29 CMS has also modified its processes for 

identifying provider billing of services that are medically unlikely to 

prevent circumvention of automated edits designed to identify an 

unusually large quantity of services provided to the same patient.30

We also evaluated the implementation of CMS’s Fraud Prevention 

System (FPS), which uses predictive analytic technologies as required by 

the Small Business Jobs Act of 2010 to analyze Medicare fee-for-service 

(FFS) claims on a prepayment basis. FPS identifies investigative leads for 

CMS’s Zone Program Integrity Contractors (ZPIC), the contractors 

responsible for detecting and investigating potential fraud.31

 

28Each Medicare administrative contractor (MAC) has the authority to develop LCDs that 

delineate the circumstances under which services are considered reasonable and 

necessary and are therefore covered in the geographic area where that MAC processes 

claims. These local policies cannot conflict with national coverage and payment policies 

established by CMS or by law. MACs’ authority to develop LCDs leads to differences in 

Medicare coverage policy in different areas of the country. MACs may create prepayment 

edits either to implement their LCDs or to implement national Medicare policies set by 

CMS, although not every LCD or national policy is structured in a way that makes edit 

development feasible. CMS has responsibility for providing information and oversight to 

MACs with respect to their use of prepayment edits to promote effective stewardship of 

Medicare funds.

Implemented 

29CMS typically develops national coverage determinations for services that have the 

potential to affect a large number of beneficiaries and that have the greatest effect on the 

Medicare program. Development of national coverage determinations is a lengthy 

process, which requires review of clinical evidence and allows for public comment.

30CMS refers to these as Medically Unlikely Edits. These edits are designed to deny 

payment for services where the number of units billed exceeds the maximum number a 

provider would bill under most circumstances for a beneficiary on a single date of service.

31GAO, Medicare Fraud Prevention: CMS Has Implemented a Predictive Analytics 

System, but Needs to Define Measures to Determine Its Effectiveness, GAO-13-104

(Washington, D.C.: Oct. 15, 2012).
 

Page 12 GAO-14-560T Medicare Fraud

in July 2011, FPS is intended to help facilitate the agency’s shift from 

focusing on recovering potentially fraudulent payments after they have 

been made, to detecting aberrant billing patterns as quickly as possible, 

with the goal of preventing these payments from being made. However, in 

October 2012, we found that, while FPS generated leads for 

investigators, it was not integrated with Medicare’s payment-processing 

system to allow the prevention of payments until suspect claims can be 

determined to be valid. As of April 2014, CMS reported that while the FPS 

functionality to deny claims before payment had been integrated with the 

Medicare payment processing system in October 2013, the system did 

not have the ability to suspend payment until suspect claims could be 

investigated. In addition, while CMS directed the ZPICs to prioritize alerts 

generated by the system, in our work examining the sources of new ZPIC 

investigations in 2012, we found that FPS accounted for about 5 percent 

of ZPIC investigations in that year.32 A CMS official reported last month 

that ZPICs are now using FPS as a primary source of leads for fraud 

investigations, though the official did not provide details on how much of 

ZPICs’ work is initiated through the system.33

Our prior work found that postpayment reviews are critical to identifying 

and recouping overpayments.34 The use of national recovery audit 

contractors (RAC)35 in the Medicare program is helping to identify 

underpayments and overpayments on a postpayment basis.36

 

32GAO, Medicare Program Integrity: Contractors Reported Generating Savings, but CMS 

Could Improve Its Oversight, 

CMS 

GAO-14-111 (Washington, D.C.: Oct. 25, 2013).

33S. Agrawal, Preventing Medicare Fraud, testimony before the Senate Special Aging 

Committee, Mar. 26, 2014. Additionally, CMS has not published a report detailing the 

results of the second year of implementation of the FPS system, as required by the Small 

Business Jobs Act of 2010. The report was due in 2013.

34See GAO, Medicare Fraud, Waste, and Abuse: Challenges and Strategies for 

Preventing Improper Payments, GAO-10-844T (Washington, D.C.: June 15, 2010).

35These contractors are also referred to as Recovery Auditors.

36Recovery auditing has been used in various industries, including health care, to identify 

and collect overpayments for about 40 years.
 

Page 13 GAO-14-560T Medicare Fraud

began the program in March 2009 for Medicare FFS.37 CMS reported 

that, as of the end of 2013, RACs collected $816 million for fiscal year 

2014.38

Other contractors help CMS investigate potentially fraudulent FFS 

payments, but CMS could improve its oversight of their work. CMS 

contracts with ZPICs in specific geographic zones covering the nation. 

We recently found that the ZPICs reported that their actions, such as 

stopping payments on suspect claims, resulted in more than 

$250 million in savings to Medicare in calendar year 2012.

PPACA required the expansion of Medicare RACs to Parts C and 

D. CMS has implemented a RAC for Part D, and CMS said it plans to 

award a contract for a Part C RAC by the end of 2014. Moreover, in 

February 2014, CMS announced a “pause” in the RAC program as the 

agency makes changes to the program and starts a new procurement 

process for the next round of recovery audit contracts for Medicare FFS 

claims. CMS said it anticipates awarding all five of these new Medicare 

FFS recovery audit contracts by the end of summer 2014.

39

 

37The Medicare Prescription Drug, Improvement and Modernization Act of 2003 directed 

CMS to conduct a demonstration of the use of RACs in identifying underpayments and 

overpayments, and recouping overpayments in Medicare. Pub. L. No. 108-173, § 306, 117 

Stat. 2066, 2256-57. Subsequently, the Tax Relief and Health Care Act of 2006 required 

CMS to implement a national RAC program by January 1, 2010. Pub. L. No. 109-432, div. 

B, title III, § 302, 120 Stat. 2922, 2991 (codified at 42 U.S.C. § 1395ddd(h)).

However, 

CMS lacks information on the timeliness of ZPICs’ actions—such as the 

time it takes between identifying a suspect provider and taking actions to 

stop that provider from receiving potentially fraudulent Medicare 

payments—and would benefit from knowing whether ZPICs could save 

more money by acting more quickly. Thus, in October 2013, we 

recommended that CMS collect and evaluate information on the 

timeliness of ZPICs’ investigative and administrative actions. CMS did not 

comment on our recommendation. We are currently examining the 

activities of the CMS contractors, including ZPICs, that conduct 

postpayment claims reviews. Our work is reviewing, among other things, 

38See Centers for Medicare & Medicaid Services, Medicare Fee for Service, National 

Recovery Audit Program, Quarterly Newsletter, accessed Apr. 17, 2014, 

http://www.cms.gov/Research-Statistics-Data-and-Systems/MonitoringPrograms/Medicare-FFS-Compliance-Programs/Recovery-AuditProgram/Downloads/Medicare-FFS-Recovery-Audit-Program-1st-qtr-2014.pdf. 

39GAO-14-111. 
 

Page 14 GAO-14-560T Medicare Fraud

whether CMS has a strategy for coordinating these contractors’ 

postpayment claims review activities.

CMS has taken steps to improve use of two CMS information technology 

systems that could help analysts identify fraud after claims have been 

paid, but further action is needed. In 2011, we found that the Integrated 

Data Repository (IDR)—a central data store of Medicare and other data 

needed to help CMS program integrity staff and contractors detect 

improper payments of claims—did not include all the data that were 

planned to be incorporated by fiscal year 2010, because of technical 

obstacles and delays in funding.40 As of March 2014, the agency had not 

addressed our recommendation to develop reliable schedules to 

incorporate all types of IDR data, which could lead to additional delays in 

making available all of the data that are needed to support enhanced 

program integrity efforts and achieve the expected financial benefits. 

However, One Program Integrity (One PI)—a web-based portal intended 

to provide CMS staff and contractors with a single source of access to 

data contained in IDR, as well as tools for analyzing those data—is 

operational and CMS has established plans and schedules for training all 

intended One PI users, as we also recommended in 2011. However, as of 

March 2014, CMS had not established deadlines for program integrity 

contractors to begin using One PI, as we recommended in 2011. Without 

these deadlines, program integrity contractors will not be required to use 

the system, and as a result, CMS may fall short in its efforts to ensure the 

widespread use and to measure the benefits of One PI for program 

integrity purposes.

 

40GAO, Fraud Detection Systems: Centers for Medicare and Medicaid Services Needs to 

Ensure More Widespread Use, GAO-11-475 (Washington, D.C.: June 30, 2011).
 

Page 15 GAO-14-560T Medicare Fraud

Having mechanisms in place to resolve vulnerabilities that could lead to 

improper payments, some of which are potentially fraudulent, is critical to 

effective program management, but our work has shown weaknesses in 

CMS’s processes to address such vulnerabilities.41 Both we and OIG 

have made recommendations to CMS to improve the tracking of 

vulnerabilities. In our March 2010 report on the RAC demonstration 

program, we found that CMS had not established an adequate process 

during the demonstration or in planning for the national program to ensure 

prompt resolution of vulnerabilities that could lead to improper payments 

in Medicare; further, the majority of the most significant vulnerabilities 

identified during the demonstration were not addressed.42 In December 

2011, OIG found that CMS had not resolved or taken significant action to 

resolve 48 of 62 vulnerabilities reported in 2009 by CMS contractors 

specifically charged with addressing fraud.43 We and OIG recommended 

that CMS have written procedures and time frames to ensure that 

vulnerabilities were resolved. CMS has indicated that it is now tracking 

vulnerabilities identified from several types of contractors through a single 

vulnerability tracking process, and the agency has developed some 

written guidance on the process. We recently examined that process and 

found that, while CMS informs MACs about vulnerabilities that could be 

addressed through prepayment edits, the agency does not systematically 

compile and disseminate information about effective local edits to address 

such vulnerabilities.44

 

41Federal internal control standards state that an agency should have policies and 

procedures to ensure that (1) the findings of all audits and reviews are promptly evaluated, 

(2) decisions are made about the appropriate response to these findings, and (3) actions 

are taken to correct or resolve the issues promptly. See GAO, Standards for Internal 

Control in the Federal Government, 

Specifically, we recommended that CMS require 

AIMD-00-21-3.1 (Washington, D.C.: November 1999). 

These are all aspects of internal control, which is the component of an organization’s 

management that provides reasonable assurance that the organization achieves effective 

and efficient operations, reliable financial reporting, and compliance with applicable laws 

and regulations. Internal control standards provide a framework for identifying and 

addressing major performance challenges and areas at greatest risk for mismanagement. 

See GAO, Internal Control Standards: Internal Control Management and Evaluation Tool, 

GAO-01-1008G (Washington, D.C.: August 2001).

42GAO, Medicare Recovery Audit Contracting: Weaknesses Remain in Addressing 

Vulnerabilities to Improper Payments, Although Improvements Made to Contractor 

Oversight, GAO-10-143 (Washington, D.C.: Mar. 31, 2010).

43Department of Health and Human Services, Office of Inspector General, Addressing

Vulnerabilities Reported by Medicare Benefit Integrity Contractors, OEI-03-10-00500 

(December 2011).

44GAO-13-102. 

Addressing Identified 

Vulnerabilities Could Help 

Reduce Fraud
 

Page 16 GAO-14-560T Medicare Fraud

MACs to share information about the underlying policies and savings 

related to their most effective edits, and CMS generally agreed to do so. 

In addition, in 2011, CMS began requiring MACs to report on how they 

had addressed certain vulnerabilities to improper payment, some of which 

could be addressed through edits.

We also recently made recommendations to CMS to address the millions 

of Medicare cards that display beneficiaries’ Social Security numbers, 

which increases beneficiaries’ vulnerability to identity theft.45

In addition, we and others have identified concerns with CMS oversight of 

fraud, waste, and abuse in Medicare’s prescription drug program, Part D, 

including the contractors tasked with this work. To help address potential 

vulnerabilities in that program, we are examining practices for promoting 

prescription drug program integrity, and the extent to which CMS’s 

oversight of Medicare Part D reflects those practices.

In August 

2012, we recommended that CMS (1) select an approach for removing 

Social Security numbers from Medicare cards that best protects 

beneficiaries from identity theft and minimizes burdens for providers, 

beneficiaries, and CMS and (2) develop an accurate, well-documented 

cost estimate for such an option. In September 2013, we further 

recommended that CMS (1) initiate an information technology project for 

identifying, developing, and implementing changes for the removal of 

Social Security numbers and (2) incorporate such a project into other 

information technology initiatives. HHS concurred with our 

recommendations and agreed that removing the numbers from Medicare 

cards is an appropriate step toward reducing the risk of identity theft. 

However, the department also said that CMS could not proceed with 

changes without agreement from other agencies, such as the Social 

Security Administration, and that funding was also a consideration. Thus, 

CMS has not yet taken action to address these recommendations. We 

are currently examining other options for updating and securing Medicare 

cards, including the potential use of electronic-card technologies.

 

45GAO, Medicare Information Technology: Centers for Medicare and Medicaid Services 

Needs to Pursue a Solution for Removing Social Security Numbers from Cards, 

GAO-13-761 (Washington, D.C.: Sept. 10, 2013) and GAO, CMS Needs an Approach and 

a Reliable Cost Estimate for Removing Social Security Numbers from Medicare Cards, 

GAO-12-831 (Washington, D.C.: Aug. 1, 2012).
 

Page 17 GAO-14-560T Medicare Fraud

Although CMS has taken some important steps to identify and prevent 

fraud, the agency must continue to improve its efforts to reduce fraud, 

waste, and abuse in the Medicare program. Identifying the nature, extent, 

and underlying causes of improper payments, and developing adequate 

corrective action processes to address vulnerabilities, are essential 

prerequisites to reducing them. As CMS continues its implementation of 

PPACA and Small Business Jobs Act provisions, additional evaluation 

and oversight will help determine whether implementation of these 

provisions has been effective in reducing improper payments. We are 

investing resources in a body of work that assesses CMS’s efforts to 

refine and improve its fraud detection and prevention abilities. Notably, 

we are currently assessing the potential use of electronic-card 

technologies, which can help reduce Medicare fraud. We are also 

examining the extent to which CMS’s information system can help 

prevent and detect the continued enrollment of ineligible or potentially 

fraudulent providers in Medicare. Additionally, we have a study underway 

examining CMS’s oversight of fraud, waste, and abuse in Medicare Part 

D to determine whether the agency has adopted certain practices for 

ensuring the integrity of that program. We are also examining CMS’s 

oversight of some of the contractors that conduct reviews of claims after 

payment. These studies are focused on additional actions for CMS that 

could help the agency more systematically reduce potential fraud in the 

Medicare program.

Chairman Brady, Ranking Member McDermott, and Members of the 

Subcommittee, this concludes my prepared remarks. I would be pleased 

to respond to any questions you may have at this time.

For further information about this statement, please contact 

Kathleen M. King at (202) 512-7114 or kingk@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs 

may be found on the last page of this statement. Karen Doran, Assistant 

Director; Stephen Robblee; Lisa Rogers; Eden Savino; and Jennifer 

Whitworth were key contributors to this statement.

Concluding 

Observations

GAO Contact and 

Staff 

Acknowledgments
Appendix I: Abbreviations

Page 18 GAO-14-560T Medicare Fraud

CMS Centers for Medicare & Medicaid Services

DMEPOS durable medical equipment, prosthetics, orthotics, and 

 supplies

DOJ Department of Justice

FFS fee-for-service 

FPS Fraud Prevention System

HHS Department of Health and Human Services

IDR Integrated Data Repository

LCD local coverage determinations

MAC Medicare administrative contractor

NPI National Provider Identifier

OIG Office of Inspector General

One PI One Program Integrity

PECOS Provider Enrollment, Chain, and Ownership System

PPACA Patient Protection and Affordable Care Act

RAC recovery audit contractor

ZPIC Zone Program Integrity Contractor

Appendix I: Abbreviations
Related GAO Products

Page 19 GAO-14-560T Medicare Fraud

Medicare: Second Year Update for CMS’s Durable Medical Equipment 

Competitive Bidding Program Round 1 Rebid. GAO-14-156. Washington, 

D.C.: March 7, 2014.

Medicare Program Integrity: Contractors Reported Generating Savings, 

but CMS Could Improve Its Oversight. GAO-14-111. Washington, D.C.: 

October 25, 2013.

Medicare Information Technology: Centers for Medicare and Medicaid 

Services Needs to Pursue a Solution for Removing Social Security 

Numbers from Cards. GAO-13-761. Washington, D.C.: September 10, 

2013

Health Care Fraud and Abuse Control Program: Indicators Provide 

Information on Program Accomplishments, but Assessing Program 

Effectiveness Is Difficult. GAO-13-746. Washington, D.C.: September 30, 

2013.

Medicare Program Integrity: Increasing Consistency of Contractor 

Requirements May Improve Administrative Efficiency. GAO-13-522. 

Washington, D.C.: July 23, 2013.

Medicare Program Integrity: Few Payments in 2011 Exceeded Limits 

under One Kind of Prepayment Control, but Reassessing Limits Could Be 

Helpful. GAO-13-430. Washington, D.C.: May 9, 2013.

2013 Annual Report: Actions Needed to Reduce Fragmentation, Overlap, 

and Duplication and Achieve Other Financial Benefits. GAO-13-279SP. 

Washington, D.C.: April 9, 2013.

Medicare Fraud Prevention: CMS Has Implemented a Predictive 

Analytics System, but Needs to Define Measures to Determine Its 

Effectiveness. GAO-13-104. Washington, D.C.: October 15, 2012.

Medicare Program Integrity: Greater Prepayment Control Efforts Could 

Increase Savings and Better Ensure Proper Payment. GAO-13-102. 

Washington, D.C.: November 13, 2012.

Medicare: CMS Needs an Approach and a Reliable Cost Estimate for 

Removing Social Security Numbers from Medicare Cards. GAO-12-831. 

Washington, D.C.: August 1, 2012.

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Page 20 GAO-14-560T Medicare Fraud

Health Care Fraud: Types of Providers Involved in Medicare, Medicaid, 

and the Children’s Health Insurance Program Cases. GAO-12-820. 

Washington, D.C.: September 7, 2012.

Program Integrity: Further Action Needed to Address Vulnerabilities in 

Medicaid and Medicare Programs. GAO-12-803T. Washington, D.C.: 

June 7, 2012.

Follow-up on 2011 Report: Status of Actions Taken to Reduce 

Duplication, Overlap, and Fragmentation, Save Tax Dollars, and Enhance 

Revenue. GAO-12-453SP. Washington, D.C.: February 28, 2012.

Medicare: The First Year of the Durable Medical Equipment Competitive 

Bidding Program Round 1 Rebid. GAO-12-733T. Washington, D.C.: 

May 9, 2012.

Medicare: Review of the First Year of CMS’s Durable Medical Equipment 

Competitive Bidding Program’s Round 1 Rebid. GAO-12-693. 

Washington, D.C.: May 9, 2012.

Medicare: Important Steps Have Been Taken, but More Could Be Done to 

Deter Fraud. GAO-12-671T. Washington, D.C.: April 24, 2012.

Medicare Program Integrity: CMS Continues Efforts to Strengthen the 

Screening of Providers and Suppliers. GAO-12-351. Washington, D.C.: 

April 10, 2012.

Improper Payments: Remaining Challenges and Strategies for 

Governmentwide Reduction Efforts. GAO-12-573T. Washington, D.C.: 

March 28, 2012.

2012 Annual Report: Opportunities to Reduce Duplication, Overlap 

and Fragmentation, Achieve Savings, and Enhance Revenue. 

GAO-12-342SP. Washington, D.C.: February 28, 2012.

Fraud Detection Systems: Centers for Medicare and Medicaid Services 

Needs to Expand Efforts to Support Program Integrity Initiatives. 

GAO-12-292T. Washington, D.C.: December 7, 2011.

Medicare Part D: Instances of Questionable Access to Prescription 

Drugs. GAO-12-104T. Washington, D.C.: October 4, 2011.
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Page 21 GAO-14-560T Medicare Fraud

Medicare Part D: Instances of Questionable Access to Prescription 

Drugs. GAO-11-699. Washington, D.C.: September 6, 2011.

Medicare Integrity Program: CMS Used Increased Funding for New 

Activities but Could Improve Measurement of Program Effectiveness. 

GAO-11-592. Washington, D.C.: July 29, 2011.

Improper Payments: Reported Medicare Estimates and Key Remediation 

Strategies. GAO-11-842T. Washington, D.C.: July 28, 2011.

Fraud Detection Systems: Additional Actions Needed to Support Program 

Integrity Efforts at Centers for Medicare and Medicaid Services. 

GAO-11-822T. Washington, D.C.: July 12, 2011.

Fraud Detection Systems: Centers for Medicare and Medicaid Services 

Needs to Ensure More Widespread Use. GAO-11-475. Washington, D.C.: 

June 30, 2011.

Improper Payments: Recent Efforts to Address Improper Payments and 

Remaining Challenges. GAO-11-575T. Washington, D.C.: April 15, 2011.

Medicare and Medicaid Fraud, Waste, and Abuse: Effective 

Implementation of Recent Laws and Agency Actions Could Help Reduce 

Improper Payments. GAO-11-409T. Washington, D.C.: March 9, 2011.

Opportunities to Reduce Potential Duplication in Government Programs, 

Save Tax Dollars, and Enhance Revenue. GAO-11-318SP. Washington, 

D.C.: March 1, 2011.

Improper Payments: Progress Made but Challenges Remain in 

Estimating and Reducing Improper Payments. GAO-09-628T. 

Washington, D.C.: April 22, 2009.

Medicare: Thousands of Medicare Providers Abuse the Federal Tax 

System. GAO-08-618. Washington, D.C.: June 13, 2008.

Medicare: Competitive Bidding for Medical Equipment and Supplies 

Could Reduce Program Payments, but Adequate Oversight Is Critical. 

GAO-08-767T. Washington, D.C.: May 6, 2008.

Improper Payments: Status of Agencies’ Efforts to Address Improper 

Payment and Recovery Auditing Requirements. GAO-08-438T. 

Washington, D.C.: January 31, 2008.
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Page 22 GAO-14-560T Medicare Fraud

Improper Payments: Federal Executive Branch Agencies’ Fiscal Year 

2007 Improper Payment Estimate Reporting. GAO-08-377R. Washington, 

D.C.: January 23, 2008.

Medicare: Improvements Needed to Address Improper Payments for 

Medical Equipment and Supplies. GAO-07-59. Washington, D.C.: 

January 31, 2007.

Medicare: More Effective Screening and Stronger Enrollment Standards 

Needed for Medical Equipment Suppliers. GAO-05-656. Washington, 

D.C.: September 22, 2005.

Medicare: CMS’s Program Safeguards Did Not Deter Growth in Spending 

for Power Wheelchairs. GAO-05-43. Washington, D.C.: November 17, 

2004.

Medicare: CMS Did Not Control Rising Power Wheelchair Spending. 

GAO-04-716T. Washington, D.C.: April 28, 2004.

(291215)
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