OIG Compendium of Priority Recommendations—Are You Ready?

by DLA Piper

What’s Happening?

The U.S. Department of Health and Human Services (“HHS”), Office of Inspector General (“OIG”) recently released the Compendium of Priority Recommendations (the “OIG Compendium”).  This annual publication provides a summary of previously identified, but not yet implemented, opportunities to “achieve cost savings, improve program management, and ensure quality of care and safety of beneficiaries.”  Health care providers routinely pay close attention to the OIG Compendium to gain further insight into the OIG’s priorities and areas of focus.

The OIG Compendium lists 25 “Priority Recommendations” that stem from previous OIG audit and evaluation reports.  Below is a snapshot of these Priority Recommendations organized according to the six categories the OIG set forth in the OIG Compendium.  The OIG also provided over 200 “key recommendations” as part of the Priority Recommendations.  While implementation of some of the key recommendations  is already underway, the OIG listed them in this report because it stated that more progress is necessary.

  1. Medicare Policies and Payments
    1. Address wasteful Medicare policies and payment rates for clinical laboratories, hospitals and hospices
    2. Improve controls to address improper Medicare billings by community mental health centers, home health agencies and skilled nursing facilities
    3. Detect and recover improper Medicare payments for services to incarcerated, unlawfully present or deceased individuals
    4. Maximize recovery of Medicare overpayments
    5. Improve monitoring and reconciliation of Medicare hospital outlier payments
    6. Medicare Part C- Ensure that Medicare Advantage Organizations are implementing programs to prevent and detect waste, fraud and abuse
    7. Medicare Part D- Improve controls to address questionable billing and prescribing practices for prescription drugs
  2. Medicare Quality of Care and Safety Issues
    1. Hospitals- Address adverse events in hospital settings
    2. Nursing homes- Improve care planning and discharge planning for beneficiaries in nursing home settings
    3. Nursing homes- Address harm to patients, questionable resident hospitalizations and inappropriate drug use
    4. Nursing homes- Improve emergency preparedness and response
    5. Hospices- Ensure compliance with Medicare Conditions of Participation
  3. Medicaid Program Policies and Payments
    1. Federal share of Medicaid- Ensure that State claims and practices do not inappropriately inflate Federal reimbursements
    2. Improper payments- Ensure that States prevent, detect and recover improper payments and return the Federal share of recoveries to the Federal Government
    3. Medicaid drug pricing- Assist States to better align drug reimbursements with pharmacy acquisition costs
    4. Ensure that Medicaid Information Systems are fully functional
    5. Address Medicaid managed care fraud and abuse concerns
  4. Medicaid Quality of Care and Safety Issues
    1. Medicaid home and community-based care settings- Ensure that service providers comply with quality and safety requirements
    2. Preventions- Ensure that States improve utilization of preventive screening services for eligible children
  5. Oversight of Food Safety
    1. Improve oversight of dietary supplements
    2. Improve oversight of food inspections and traceability
  6. HHS Grants and Contracts
    1. Grants- Improve oversight of grantee compliance, quality assurance and conflicts of interest
    2. Contracts- Improve oversight of Medicare contractor performance and conflicts of interest
  7. HHS Financial Stewardship
    1. Reduce improper payments and fraud
    2. Correct deficiencies found in financial statement audits

Questions to Consider

  • Which elements of the OIG Compendium do you believe will receive the greatest attention?
  • Which recommendations listed in the OIG Compendium do you believe should receive the greatest attention?
  • Will you change any of your compliance monitoring activities in light of the OIG Compendium?
  • Do you think the OIG should have listed anything else in the OIG Compendium?

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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