On Halloween the Office of Inspector General (OIG) of Health & Human Services released its “Work Plan Fiscal 2015.”  The 90-page document is meant to tell the public, and especially health care providers paid by Medicare and Medicaid, where the OIG intends to focus its investigative time and resources during fiscal 2015.

Hospitals should be aware that the areas of focus in the hospital industry include (i) reconciliation of outlier payments, (ii) the impact of new inpatient admission criteria on hospital billing, (iii) charges connected with defective medical devices, (iv) analysis of salaries and compensation included in cost reports, (v) oversight of provider-based status, (vi) comparison of provider-based and free-standing clinics, and (vii) payment policy for swing beds in critical access hospitals.

Regarding item (iv), the Work Plan includes the ominous reminder that only “reasonable remuneration” for services may be included in Medicare cost reports.

It’s noteworthy that two of the seven enumerated areas of focus—items (v) and (vi)—address an issue of growing concern to governmental and commercial payers alike.  That’s the “provider-based” issue that arises when a hospital owns and operates an ambulatory facility and can therefore charge higher, hospital rates than if the facility were free-standing (as it may have been before the hospital acquired it).  The concern is that payers pay more for the same services.  So do patients, through higher deductibles and co-payments.