On March 18, 2014, the OIG released its Compendium of Priority Recommendations (Compendium), which lists 25 broad “Priority Recommendations” for achieving “cost savings, improve program management, and ensure quality of care and safety of beneficiaries.”  The 25 recommendations are grouped into seven categories based on the underlying HHS program or operation. The seven recommendations relating to “Medicare Policies and Payments” are listed below:

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.

The OIG focuses on three specific recommendations for eliminating “wasteful” payment policies for hospitals:  1) “expand the DRG window to include additional days prior to the inpatient admission,” 2) “expand the DRG window to include other hospital ownership arrangements, such as affiliated hospital groups,” and 3) “establish a hospital transfer payment policy for early discharges to hospice.”

Each recommendation in the Compendium is derived from more specific recommendations that the OIG has made in audit and evaluation reports, which are referenced in the Compendium. Since the Compendium reflects unimplemented past or present recommendations, it does not reflect “work currently underway in OIG on many emerging issues, including analyzing the implementation of programs established by the Patient Protection and Affordable Care Act.”

In addition to the “Medicare Policies and Payments” category discussed above, the Compendium includes recommendations in the following broad categories:  1) Medicare Quality of Care and Safety Issues, 2) Medicaid Program Policies and Payments, 3) Medicaid Quality of Care and Safety Issues, 4) Oversight of Food Safety, 5) HHS Grants and Contracts, and 6) HHS Financial Stewardship.

Reporter, Daniel J. Hettich, Washington, D.C., +1 202 626 9128, dhettich@kslaw.com.