Updated on: January 31, 2013

Update Your Compliance Program with New OIG Work Plan Targets

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Original story posted on: October 20, 2011

k-longWhile the RACs were quiet last week, the Office of Inspector General (OIG) posted its own audit targets to keep providers busy.

The OIG's 2012 Work Plan, released Oct. 5, gives providers insight into areas where the OIG sees potential for problems and where providers might need to bolster their compliance programs.

Here are some of the highlights from the Work Plan:

  • Home health has five new issues, including "questionable billing characteristics of home health services" that might reveal potential fraud. The issue was posted at almost the same time that the Senate Finance Committee published a report alleging evidence of fraud in home health therapy services at three of the four biggest home health companies.
  • For hospitals, six of the 23 issues are new. One new issue examines the appropriateness of admissions to inpatient rehabilitation facilities and another investigates critical access hospitals' size, services and distance from other hospitals.
  • OIG posted eight issues for nursing homes, of which three are new. For Medicare- and Medicaid-certified nursing homes, auditors will review whether the facilities' compliance plans incorporate OIG compliance program guidance and whether the plans are part of "day-to-day operations," the Work Plan stated.
  • Hospices have just two issues. The one new issue - hospice marketing practices and financial relationships with nursing facilities - follows a Medicare Payment Advisory Commission (MedPAC) note that "hospices and nursing facilities may be involved in inappropriate enrollment and compensation," the Work Plan notes.
  • Four of the fourteen issues are new for medical and equipment supplies providers. The new issues include effectiveness of edits to prevent payments to multiple suppliers of home blood-glucose testing supplies, questionable billing for Medicare diabetic testing supplies, support surface pricing and collection of surety bonds for overpayments made to suppliers of durable medical equipment.

OIG posted several issues for physicians under the "other providers and suppliers" section, including new issues such as incident-to services, use of modifiers during the global period and high cumulative Part B payments.

About the Author

Karen Long is the compliance product manager 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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