Medicare's Policies and Procedures Identified Almost All Improper Claims Submitted for Deceased Individuals and Recouped Almost All Improper Payments Made for These Claims for January 2013 Through October 2015

CMS had policies and procedures to ensure that payments were not made for Medicare services ostensibly rendered to deceased individuals. These policies and procedures generally ensured that CMS did not make improper payments when its data systems indicated at the time a claim was processed that the individual had died before the claimed date of service. These policies and procedures also ensured that CMS correctly identified and recouped improper payments for almost all of the cases in which the Enrollment Database (EDB) was updated with date-of-death information after the claims had been processed and paid.

CMS, however, did not identify and recoup all improper payments. Specifically, for our audit period we identified $426,000 in improper payments for 427 Medicare claims and $1.5 million in potentially improper payments for 1,047 Medicare claims with dates of service that were after the individuals' dates of death. These improper and potentially improper payments represented 0.0002 percent of the total Parts A and B payments made during this period. In addition, these claims represented only 0.15 percent of the Medicare claims in which the EDB had been updated with date-of-death information after the claims had been processed and paid.

We recommended that CMS (1) direct Medicare contractors to initiate recoupment for $415,000 in improper payments associated with the 332 claims whose dates of service were after the individuals' dates of death; (2) confirm that the $11,000 in improper payments associated with the 95 claims that we identified have been recouped; and (3) review the accuracy of the beneficiary dates of death in its data systems to determine whether any of the $1.5 million relating to the 1,047 claims with conflicting date-of-death information were improper payments, and if so, direct Medicare contractors to initiate recoupment for the identified amounts.