OIG Initiates Monthly Updates to its Work Plan and Adds New Items

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The HHS Office of Inspector General (OIG) recently announced that, effective June 15, 2017, the agency will update its Work Plan website monthly instead of only once or twice per year. In developing its Work Plan, OIG assesses risks in HHS programs and operations to identify areas requiring the most attention, and OIG provides that the monthly updates are to ensure that the agency more closely aligns with the work planning process.

OIG’s list of recently added items updated in July 2017 include 14 new inquiries, and set forth below are certain of the new items to watch for:

  • Medicare Part B Payments for Ambulance Services Subject to Part A Skilled Nursing Facility Consolidated Billing Requirements: Prior OIG reports have identified high error rates and overpayments for services subject to skilled nursing facility (SNF) consolidated billing, and pursuant to this new item for review, OIG will determine whether ambulance services paid by Medicare Part B were subject to Part A SNF consolidated billing requirements. A summary of OIG’s review of this item is available here.
  • Children’s Health Insurance Program Reauthorization Act (CHIPRA) Performance Bonus Payments Received by States: OIG will evaluate whether performance bonus payments for Federal fiscal years 2009 through 2013 were allowable in accordance with Federal requirements, and OIG’s summary of this item is available here.
  • High-Risk, Error-Prone HHA Providers Using HHA Historical Data: There has been an alleged error rate of approximately 42 percent ($7.7 billion) of improper Medicare home health claims based on a 2016 report, and OIG will use data from CMS’s Comprehensive Error Rate Testing program to identify the common characteristics of “at risk” HHA providers that could be used to monitor pre- and post-payment review of home health claims. See more regarding this review here.
  • Nationwide Medicare Electronic Health Record Incentive Payments to Hospitals: Prior OIG studies have identified that, due to allegedly inaccurate hospital calculations, State agencies overpaid hospitals by $66.7 million for Medicaid electronic health record (EHR) incentive payments and anticipate that States will overpay these hospitals an additional $13.2 million in the future. OIG will review the hospitals’ incentive payment calculations to identify potential overpayments that the hospitals would have received as a result of the alleged inaccuracies. See more regarding this review here.
  • Review of Medicare Payments for Nonphysician Outpatient Services Provided Under the Inpatient Prospective Payment System (IPPS): According to earlier OIG reviews, the agency allegedly identified significant overpayments to hospital outpatient providers for nonphysician services furnished shortly before or during inpatient stays. OIG’s objective is to analyze national data to determine whether Medicare payments to hospital outpatient providers were correct for nonphysician outpatient services provided within three days prior to the date of admission, on the date of admission, or during IPPS stays (excluding date of discharge). A description of this OIG item is available here.

OIG will also target as part of its new Work Plan items, among other things, a review of Medicare payments for telehealth services, Medicare payments for unallowable overlapping home health claims and Part B claims, Medicare payments for unallowable overlapping hospice claims and Part B claims, and Medicaid claims for opioid treatment program services.

All of the recently added Work Plan items have an expected issue date of 2018 and the full list of new items is available here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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