As Veterans Day approaches, the Centers for Medicare & Medicaid Services (CMS) has moved to continue a computer matching program used to identify and recover duplicate payments for veterans’ healthcare. In an October 21 notice in the Federal Register, CMS described a new agreement with the Department of Veterans Affairs (VA), Veterans Health Administration (VHA), that would carry forward a program the two agencies have operated since June 2024. The notice comes amid the Trump administration’s broader push against improper payments, including 2025 executive orders on interagency data sharing and payment integrity.
Because the Privacy Act limits computer matching agreements to 18 months (with a possible renewal of up to one year), continuing the program beyond the existing agreement, which has already been renewed once and runs through December 23, 2026, requires a new agreement.
About 5.9 million veterans are enrolled in both Medicare and VA healthcare, according to VA. Dual eligibility is not itself a problem. Duplicate payments arise when Medicare pays for care VA has authorized. Under section 1862(a)(3) of the Social Security Act and related VA regulations and CMS guidance, VA is responsible for paying for community care it authorizes, and Medicare generally should not pay, even before VA has paid.
A long-running problem
A 2023 HHS Office of Inspector General (OIG) audit found that Medicare made duplicate payments of up to $128 million on 298,527 claims for VA-authorized community care from 2017 through 2021. The duplicates spanned inpatient, outpatient, professional, home health, skilled nursing facility, and durable medical equipment services. As of August 2022, about 60 percent of the duplicate claims had not been canceled or adjusted.
OIG attributed the duplicates to missing controls. CMS had no comprehensive data-sharing agreement with VHA, no process to bring VHA data into its Integrated Data Repository, no internal process such as claims edits to catch duplicates, and no sufficiently clear guidance telling providers not to bill Medicare for VA-authorized care. CMS agreed with all four of OIG’s recommendations.
From audit to recoveries
CMS and VHA established the matching program in June 2024. CMS is responsible for most recoveries, while VHA recovers certain duplicate payments involving non-VA emergency care. Based on 2019 claims data, the agencies projected first-year recoveries of $42.5 million for CMS and $2.5 million for VHA. The agencies do not appear to have publicly reported actual recovery totals.
CMS issued recovery instructions to Medicare Administrative Contractors (MACs) in April 2025. In MLN Matters MM13694, CMS said recoveries would be phased in for dates of service from June 6, 2019, forward. Affected providers see Claim Adjustment Reason Code 16 with group code CO, and Remittance Advice Remark Codes M79 and MA67.
In July 2025, VA announced that a six-year review with CMS had identified about $106 million in duplicate billing, an announcement that appears to describe the 2024 program. How that figure relates to OIG’s $128 million is unclear. The review periods likely overlap, so the numbers should not be added together.
What the new notice says
Under the successor program, VHA will regularly send CMS identifying information for its enrollees so CMS can find those also enrolled in Medicare. VHA will then send claims it paid for those individuals, and CMS will return information on Medicare claims paid for the same services. Exchanged data include dates and places of service, provider identifiers, procedure and diagnosis codes, and payment amounts.
The notice does not indicate whether the program’s scope or operations will change. Like the 2024 notice, it cites authorities covering both community care and certain non-VA emergency care. Under the 2024 agreement, match results were used for actions affecting providers and suppliers, not beneficiaries, and the agencies committed to verifying matches before seeking recovery and giving providers a chance to contest.
Recovery versus prevention
OIG has closed three of its four recommendations: provider guidance in August 2024, and data sharing and an internal process to address duplicates in September 2026. Integrating VHA data into CMS’s Integrated Data Repository remains open, with an update expected March 16, 2027.
Despite those closures, a key question remains. CMS has documented procedures for recovering duplicate payments after the fact, and the 2024 agreement relies on provider education to reduce future duplicates. Public materials do not show whether CMS has added prepayment edits to stop duplicates before they are paid.
What it means for providers
For providers, the matching program is not new. Recoupments have been under way since 2025, and the successor agreement would continue them. Services VA has authorized should be billed to VA, not Medicare, even while VA payment is pending. Providers receiving adjustments under the program will see the remittance codes described above and can direct questions to their MAC. For veterans, the program affects how payments are coordinated, not their eligibility for either program.
With three audit recommendations closed and recoupments under way, the next markers to watch are recovery results, progress on data integration, and whether the agencies move from recovering duplicate payments to preventing them.
