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p.7

Increase in Compliance Risk

 $76.5 million owed to Medicaid from a New York hospital because of   

   overbilling1

 42% of improper payments identified by Recovery Audit Contractors

   are attributed to improper coding2

 38 states had either proposed or passed legislation related to pricing

   transparency as of September 20073

 $2.2 billion expected recoveries from fraud investigations and audits

   by the OIG in the first-half FY 20084

1.

Medicaid Fraud Control Units: 2005 Annual Report

2.

HealthLeaders: When the Auditor Comes Calling: Surviving an Audit (June 2008)

3.

Healthcare Financial Management: Is Your Strategic Pricing Strategy Based on Fact or Myth? (May 2008)

4.

Office of Inspector General: OIG Reports More Than $2 Billion in Recoveries From Fighting Fraud, Waste, and Abuse for First-Half FY 2008 (June 12, 2008)

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