The Office of Inspector General (OIG) of the Department of Health and Human Services recently released a Mid-Year Update to its 2016 Fiscal Year Work Plan: http://oig.hhs.gov/reports-and-publications/archives/workplan/2016/WorkPlan_April%202016_Final.pdf. The Mid-Year Update gives long-term care providers a preview of the OIG’s regulatory enforcement focus during the remainder of the current fiscal year.

Some highlights from the Mid-Year Update include:

Skilled Nursing Facility Prospective Payment System Requirements

The OIG will review compliance with the skilled nursing facility (SNF) prospective payment system requirement that a beneficiary must be an inpatient of a hospital for at least 3 consecutive days before being discharged from the hospital, in order to be eligible for SNF services. Prior OIG reviews found that Medicare payments for SNF services were not compliant with the 3-day hospital stay requirement.

Potentially Avoidable Hospitalizations of Medicare and Medicaid Eligible Nursing Home Residents for Urinary Tract Infections

The OIG will review nursing home records of residents hospitalized for urinary tract infections (UTIs), to determine whether the nursing homes provided services to prevent or detect UTIs in accordance with their care plans before the residents were hospitalized.

National Background Check Program for Long-Term-Care Employees

The OIG will review current State procedures for conducting background checks on prospective employees and providers who have direct access to patients, and determine the costs of conducting background checks. The goal is to determine the effectiveness of the States’ programs and determine whether the checks led to any unintended consequences.

State Agency Verification of Deficiency Corrections

The OIG intends to determine whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys, noting that a prior OIG review found that one State survey agency did not always verify that nursing homes corrected deficiencies identified during surveys, in accordance with Federal requirements.

Medicaid Beneficiary Transfers from Group Homes and Nursing Facilities to Hospital Emergency Rooms

The OIG will review the rate of and reasons for transfer from group homes or nursing facilities to hospital emergency departments, as high occurrences of emergency transfers could indicate poor quality of care.

Managed Long-Term-Care Reimbursements

States’ reimbursements to managed long-term-care (MLTC) plans will be examined to determine whether they complied with Federal and State requirements, including those relating to eligibility and enrollment of beneficiaries.