October 9, 2012

OIG Releases 2013 Targets in Work Plan

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It’s time to update your compliance plans with the latest targets from the HHS Office of Inspector General (OIG).

OIG listed some new and many familiar audit targets in its 2013 Work Plan released Oct. 2. Here’s a breakdown of the new topics for providers and suppliers:

  • Hospitals – inpatient billing for Medicare beneficiaries, diagnosis-related group window, non-hospital-owned physician practices using provider-based status, compliance with Medicare’s transfer policy, payments for canceled surgical procedures, payments for mechanical ventilation, quality improvement organizations’ work with hospitals and acquisitions of ambulatory surgical centers’ impact on Medicare spending. A new target for critical access hospitals is payments for swing-bed services, and for long-term care hospitals, an issue looking at payments for interrupted stays.
  • Nursing homes: stage agency verification of deficiency corrections, use of atypical antipsychotic drugs and oversight of the minimum data set submitted by long-term care facilities.
  • Home health services: home health face-to-face requirement and employment of home health aides with criminal convictions.
  • Medical equipment and supplies: quality standards – accreditation of medical equipment suppliers; lower-limb prostheses – supplier compliance with payment requirements; power mobility devices – supplier compliance with payment requirements; vacuum erection systems – reasonableness of Medicare’s fee schedule amounts compared with amounts paid by other payers; continuous positive airway pressure supplies – reasonableness of Medicare’s replacement of supplies compared with that of other federal programs; diabetes testing supplies – improper supplier billing for test strips in competitive bidding areas and supplier compliance with requirements for non-mail-order claims.
  • Other providers and suppliers: program integrity – onsite visits for Medicare provider and supplier enrollment and re-enrollment, improper use of commercial mailboxes, payments to providers subject to debt collection; anesthesia services – payments for personally performed services; ophthalmological services – questionable billing; rural health clinics – compliance with location requirements; electrodiagnostic testing – questionable billing; claims-processing errors – Medicare payments for Part B claims with G modifiers.
  • Prescription drugs: ethics – conflicts of interest involving prescription drug compendia; patient safety and quality of care – physicians’ experiences with drug shortages, hospitals’ experiences with drug shortages, manufacturer sales of prescription drugs in short supply; potential savings from manufacturer rebates for Part-B drugs; payments for immunosuppressive drug claims with KX modifiers; payments for drug infused through medical equipment compared with provider acquisition costs; payments for prostate cancer drugs under current policy.

For more, visit the OIG Work Plan website at https://oig.hhs.gov/reports-and-publications/workplan/index.asp.

RAC News

Region D recovery auditor (RAC) HealthDataInsights posted three issues last week. Two of the issues for skilled nursing facilities apply to California, Hawaii and Nevada while the one issue for outpatient hospitals affects all of the states in region D.

Skilled nursing facility (SNF)

Name of issue

Date posted or approved

Regions/states where it is active

Description of issue

Document sources

Excessive units SNF 30-day assessment

9/7/12

Calif., Hawaii, Nev.

The “30-day” Medicare MDS assessment type authorizes coverage and payment for a maximum of 30 days.

Federal Register 63 FR 26252; Medicare Skilled Nursing Facility Manual change request 2362

Excessive units SNF 60-day assessment

9/7/12

Calif., Hawaii, Nev.

The “60-day” Medicare MDS assessment type authorizes coverage and payment for a maximum of 30 days.

Federal Register 63 FR 26252; Medicare Skilled Nursing Facility Manual change request 2362

Outpatient hospital

Name of issue

Date posted or approved

Regions/states where it is active

Description of issue

Document sources

Sipuleucel-T (Provenge) – excessive units

8/10/12

RAC Region D

The recommended course of therapy for sipuleucel-T (Provenge) is three complete doses, given at approximately two-week intervals. Sipuleucel-T is supplied as a single sealed, patient-specific infusion bag and is administered via intravenous infusion over a period of approximately 60 minutes.

CMS Pub. 100-02 chapter 15; Drug Compendium, Elsevier/Gold Standard; Drug Compendium, Micromedex; Sipuleucel-T (Provenge) package insert; FDA website

About the Author

Karen Long is the editor of Physician Solutions for DecisionHealth and oversees products that relate to fraud and abuse and HIPAA compliance for physician offices and home health agencies, and accreditation compliance for hospitals. In her almost four years at DecisionHealth, Karen also has been the compliance editor and a reporter for Home Health Line, nation's leading independent authority on home healthcare business, regulation and reimbursement.

Contact the Author

KLong@decisionhealth.com

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Karen Long

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