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The Procedure That Bills More in Florida Than in 49 States Combined

Medicare billing Floridageographic variation MedicareMedicare fraud hotspotsstate Medicare spending comparisonCMS utilization outliers

Florida providers collected $26.4 million out of $46.4 million in total national Medicare payments for overnight oxygen saturation measurement (HCPCS 94762) in the most recent data. That's 56.8% of all national payments for a single procedure code, from a state that holds 6.55% of the country's Medicare providers.

The gap between Florida's payment share and its service share tells the more precise story. Florida performed 51.69% of national services for 94762, but captured 56.8% of the payments. That 5-percentage-point spread between doing the work and collecting the money is the kind of anomaly that tends to attract auditors.

One Code, One State, More Than Half the Money

Overnight oxygen saturation measurement is a high-volume, low-complexity test. Nationally, providers billed it 2.17 million times. Florida alone accounted for 1.12 million of those services. No other procedure code with comparable national volume shows Florida's payment concentration this high.

The comparison to other concentrated codes makes 94762 stand out further. Florida's payment share for Cystatin C testing (HCPCS 82610) is 32.89%. For microscopic genetic examination (HCPCS 88374), it's 41.29%, though that code shows its own anomaly: Florida provided 31.84% of national services but collected 41.29% of payments, a gap of nearly 10 percentage points. For skin and muscle removal (HCPCS 11043), a $404 million national code, Florida's 34.1% payment share tracks closely with its 32.79% service share. Code 94762 is the outlier among outliers.

For Medicare beneficiaries, this concentration means that a routine overnight monitoring test is being billed at a rate that, if distributed proportionally to Florida's population, would be roughly 8 times what you'd expect. That's not a rounding error.

The Clinical Lab Multiplier

Zoom out from individual procedure codes and the specialty-level data reinforces the same pattern. Florida's 389 Clinical Laboratory providers generated $4.93 billion in total Medicare payments, averaging $12.67 million per provider. That's 23.91 times the national average payment per clinical lab provider.

Ambulance Service Providers in Florida average $10.1 million per provider, 19 times the national ratio. Ambulatory Surgical Centers average $6.0 million per provider, 11.33 times the national figure. These aren't small specialties with noisy averages. The clinical lab figure alone, $4.93 billion from 389 providers, represents a concentration of billing that has no obvious clinical explanation rooted in Florida's population size or age distribution.

Florida's 1,813 Ophthalmology providers generated $6.68 billion in total Medicare payments, the highest absolute specialty total in the state. At $3.68 million per provider, that's 6.95 times the national average. Florida has an older population, and cataract surgery is common. But a ratio nearly 7 times the national norm still demands scrutiny.

A Declining Share That Doesn't Explain the Anomalies

Florida's overall share of national Medicare Part B spending has actually fallen over the past decade, from 9.8% in 2013 to 9.48% in 2023. Its provider count grew from 55,199 to 77,006 over the same period, a 39.5% increase, while its payment share dropped 32 basis points. On the surface, that looks like convergence toward the mean.

But aggregate trends can mask what's happening at the procedure level. Florida's provider share of the national total grew from 6.07% in 2013 to 6.55% in 2023. Its payment share, at 9.48%, remains nearly 3 percentage points above that. The state consistently bills at a rate well above its provider footprint, even as the overall gap narrows.

The 94762 concentration, 56.8% of national payments from a state with 6.55% of providers, sits at the extreme end of a distribution that has been persistently skewed toward Florida for over a decade. The overall share is trending down. The outlier codes are not.

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