On October 31, 2014, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) released its Work Plan for Fiscal Year 2015 (“Work Plan”). The Work Plan describes the various projects OIG plans to address in the upcoming year. Some of the key new and ongoing initiatives include the following:

  • Hospital wage data used to calculate Medicare payments. OIG will review hospital controls over reporting of wage data used to calculate the wage indexes for Medicare payments. Prior OIG work identified hundreds of millions of dollars in incorrectly reported wage data. 
  • Hospitals’ electronic health record system contingency plans. OIG will determine the extent to which hospitals are in compliance with electronic health record system contingency planning requirements under the Health Insurance Portability and Accountability Act (“HIPAA”). HIPAA requires hospitals to have a contingency plan established policies and procedures for responding to emergency situations that damage systems containing protected health information. 
  • Independent clinical laboratory billing requirements. OIG will review Medicare payments made to independent clinical laboratories to identify improper claims and recommend the recovery of any overpayments. Prior OIG work revealed that independent clinical laboratories were at risk for noncompliance with Medicare billing requirements.
  • Medicaid beneficiary transfers from group homes and nursing facilities to hospital emergency rooms. OIG will review the rate and reasons for the transfer of Medicaid beneficiaries from group homes and nursing home facilities to hospital emergency rooms. Prior OIG examination raised concerns regarding the quality of care provided at group homes and nursing home facilities.

The Work Plan also includes several new initiatives around the implementation and operation of Affordable Care Act programs such as the Pioneer ACO model and health insurance exchanges or marketplaces. To preview of all of the enforcement priorities planned for 2015, download the entire plan here.