OIG Releases Mid-Year Update to its Work Plan – On May 28, 2015, the OIG published a revised version of its Work Plan for Fiscal Year (FY) 2015.  As previously reported, the original version of the FY 2015 Work Plan was published in October and summarized the OIG's ongoing reviews as well as new activities the OIG planned to pursue during FY 2015.  According to the OIG, the revised edition of the Work Plan removes items that have been completed, postponed, or canceled, and adds new items that have been initiated since October 2014. 

The revised Work Plan indicates that the OIG plans to pursue the following additional initiatives that were not included in the original Work Plan:

• Reviewing outpatient payments for Intensity-Modulated Radiation Therapy (IMRT);
• Reviewing hospital preparedness and responses to high-risk infectious diseases;
• Reviewing the effects of the competitive bidding program on Medicare beneficiaries' access to certain types of durable medical equipment (DME);
• Analyzing the appropriateness of Medicare payments for clinical diagnostic laboratory tests;
• Reviewing compliance with various aspects of the Inpatient Rehabilitation Facility (IRF) Prospective Payment System (PPS) requirements, including required documentation for IRF claims;
• Reviewing the extent to which providers participating in Accountable Care Organizations (ACOs) in the Medicare Shared Savings Program use electronic health records (EHR) to exchange health information and achieve their care coordination goals;
• Summarizing the OIG's oversight portfolio, including audits, evaluations, legal opinions, and investigative work to provide progress information and recommendations to improve the Medicare Part D program;
• Describing billing trends in Medicare Part D billings from 2006 to 2014 for commonly-abused opioids;
• Reviewing state's reporting of the Federal share of Medicaid rebate collections to determine whether states are correctly identifying and reporting increases in rebate collections;
• Analyzing generic drug prices to evaluate price increases relative to inflation;
• Reviewing drug manufacturers' treatment of sales of authorized generics in the calculation of Average Manufacturer Price (AMP) for the Medicaid drug rebate program; and
• Reviewing the Food and Drug Administration's (FDA) monitoring efforts for imported food recalls.

Several initiatives were removed from the Work Plan, including:

• Reviewing critical access hospitals (CAH) payments for swing bed services;
• Reviewing outpatient evaluation and management (E/M) services to determine the appropriateness of new and established patient codes;
• Overseeing pharmaceutical compounding in Medicare-participating acute care hospitals;
• Reviewing hospitalizations of nursing home residents for manageable and preventable conditions;
• Reviewing the extent to which hospices serve beneficiaries residing in Assisted Living Facilities (ALFs);
• Reviewing the extent to which the FDA inspects generic drug manufacturers;
• Reviewing Medicare outpatient payments for drugs such as chemotherapy drugs to determine whether Medicare overpaid providers due to incorrect coding or overbilling of units;
• Examining the security controls regarding networked medical devices in hospitals to ensure beneficiary safety and that any associated electronic protected health information (ePHI) is secured; and
• Reviewing State allocation of Medicaid administrative costs.

The Work Plan, including its revisions, provides valuable insight into the OIG's enforcement priorities.  The changes summarized above are only select highlights and interested parties should review the entire plan, which is available here.

Reporter, Isabella Edmundson, Atlanta, GA, + 1 404 572 3527, iedmundson@kslaw.com.