Earlier this month, the Centers for Medicare & Medicaid Services (CMS) posted the results of the fiscal year (FY) 2009 Comprehensive Error Rate Testing (CERT) program. According to the report , the national error rate for Medicare fee-for-service claims increased from 3.6 percent in FY 2008 to 7.8 percent in FY 2009.  CMS projects that the 7.8 percent error rate reflects approximately $23.0 billion in overpayments and $1.1 billion in underpayments. ...