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  • Incorrectly apportioning costs on cost reports;
  • Including costs of non-covered services, supplies, or equipment in allowable costs;
  • Arrangements by providers with employees, independent contractors, suppliers, and others that appear to be designed primarily to overcharge the program through various devices (commissions, fee splitting) to siphon-off or conceal illegal profits;
  • Billing Medicare for costs not incurred or which were attributable to non-program activities, other enterprises, or personal expenses;
  • Repeatedly including unallowable cost items on a provider's cost report except for purposes of establishing a basis for appeal;
  • Manipulation of statistics to obtain additional payment, such as increasing the square footage in the outpatient areas to maximize payment;
  • Claiming bad debts without first genuinely attempting to collect payment;
  • Certain hospital-based physician arrangements and amounts also improperly paid to physicians;
  • Amounts paid to owners or administrators that have been determined to be excessive in prior cost report settlements;
  • Days that have been improperly reported and would result in an overpayment if not adjusted;
  • Depreciation for assets that have been fully depreciated or sold;
  • Depreciation methods not approved by Medicare;
  • Interest expense for loans that have been repaid for an offset of interest income against the interest expense;
  • Program data where provider program amounts cannot be supported;
  • Improper allocation of costs to related organizations that have been determined to be improper; and
  • Accounting manipulations.
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