Summary
On November 10, 2016, the U.S. Department of Health and Human Services, Office of Inspector General (“OIG”) posted its work plan (the “Work Plan”) for fiscal year 2017. The OIG publishes its Work Plan on an annual basis. The Work Plan describes the OIG’s current and proposed audits and evaluations. The 2017 Work Plan describes more than 40 new areas (since April 2016) where the OIG will focus its efforts over the upcoming fiscal year and an update with respect to completed reviews and reports during the past fiscal year.
The release of the Work Plan is a blueprint for providers, payors and other participants in the health care delivery system to understand where and how OIG intends to spend its resources during the 2017 fiscal year. The Work Plan is important because it is an opportunity to understand the OIG’s areas of focus and proactively confirm compliance and ensure business activities are consistent with relevant statutes and regulations.
The Work Plan includes four major categories: (1) Centers for Medicare & Medicaid Services (“CMS”); (2) Public Health Reviews; (3) Human Services Reviews; and (4) Other HHS-Related Reviews. CMS is further divided into the following six parts: Medicare Parts A and B; Medicare Parts C and D; Medicaid; Health Insurance Marketplaces; Electronic Health Records; and CMS-Related Legal and Investigative Activities. This breakdown allows participants in the health care delivery system to focus on those categories or subsections most relevant or important to their businesses.
New OIG initiatives for fiscal year 2017 described in the Work Plan include:
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Reimbursement for hospital-provided hyperbaric oxygen therapy services;
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Medical Assistance days claimed by hospitals;
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Inpatient psychiatric facility outlier payments;
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Intensive therapy provided by inpatient rehabilitation hospitals;
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Unreported incidents of potential abuse and neglect in skilled nursing facilities;
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Skilled nursing facility reimbursement for therapy services;
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Review of hospices’ compliance with Medicare requirements;
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Frequency of nurse on-site visits in hospice home care;
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Medicare Part B payments for durable medical equipment, prosthetics and orthotics during non-Part A stays in skilled nursing facilities;
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Monitoring payments for clinical diagnostic laboratory tests;
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Medicare payments for chronic care management;
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Review of CMS’ implementation of the Quality Payment Program;
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Medicare Advantage payments for dates of service after an individual’s death;
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Questionable billing for compounded topical drugs under Medicare Part D; and
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Accountable care in Medicaid.
The Work Plan is available here.
