On October 1, 2008, the OIG issued its FY 2009 Work Plan (Work Plan). The Work Plan is a goal of projects and reviews that the OIG intends to undertake, and often it previews areas that the OIG or other government agencies will investigate in upcoming years. As in past years, the OIG intends to review a wide variety of areas, touching every type of provider, Medicare Part C and D plans, and areas traditionally reviewed by the FDA.
Among the highlights in this Work Plan:
Provider-Based Status/Physician Practices: Extending an ongoing audit, the OIG will review whether hospitals are properly claiming provider-based status. Typically, this status provides the hospital with enhanced reimbursement versus freestanding facilities. The audit will include physician practices that hospitals have designated as provider-based.
Physician Place of Service Coding: Tied in with the review of provider-based status, the OIG will examine whether physicians are using the proper place of service codes when billing for physician services furnished either in an ambulatory surgical center or hospital outpatient department.
Physician Reassignment: Citing problems in certain regions, the OIG will review compliance with the Medicare reassignment of benefit rules.
Physician Referrals for Home Health Agency Services: The OIG will review physician referral trends and review whether referrals for services are consistent with CMS requirements.
Outpatient Physical Therapy: The OIG will examine utilization trends in outpatient physical therapy, focusing on therapists that have a high utilization rate.
EMTALA: An area that is seemingly in perpetual audit, the OIG will again review hospital compliance with EMTALA and discrepancies in EMTALA-alleged violations in different regions.
Lab Unbundling: Some may be reminded of the 1990s and the lab unbundling cases, but CMS will again review lab unbundling to determine whether laboratories are using different mechanisms to unbundle tests.
The OIG lists approximately 100 areas that may be reviewed as part of its Work Plan, available online