On October 1, 2007 the Department of Health and Human Services, Office of Inspector General (the "OIG") posted its fiscal year 2008 Work Plan. The 2008 Work Plan outlines initiatives that the OIG plans to address in the coming fiscal year through audits, evaluations and inspections, and the OIG counsel's office.
Key 2008 Work Plan initiatives for hospitals and physicians include:
Key Hospital Initiatives
- Hospital Capital Payments -to review appropriateness of hospital expenditures for assets such as equipment and facilities.
- Inpatient Prospective System Wage Indices -to ensure hospital compliance with wage data reporting requirements.
- Inpatient Hospital Payments for New Technologies- to determine whether claims meet criteria and appropriately reflect costs for new devices and technologies.
- Long Term Care Hospitals -to review payments for interrupted stays, short stay outliers, and transfers to onsite providers with readmissions to long term care hospitals.
- Critical Access Hospitals- to determine whether classification criteria have been met and whether payments are appropriate.
- Medicare and Medicaid Disproportionate Share Hospital ("DSH") Payments -to review DSH payment regulatory compliance , calculation methodology, and hospital classifications, as well as amounts of uncompensated care.
- Provider Bad Debts -to review appropriateness of bad debt claims by hospitals, long term care hospitals, inpatient rehab facilities, psychiatric facilities, and SNFs.
- Medicare Transfer Policy -to examine improper coding of patient transfers as patient discharges.
- Payments for Diagnostic X-Rays in ER- to determine appropriateness of payments.
- Patient Care Safety in Physician-Owned Specialty Hospitals- to examine indicators of patient safety in physician-owned hospitals.
- The Joint Commission Hospital Accreditation Process- to evaluate the extent and adequacy of CMS policies on the accreditation process.
- Medicare Secondary Payer- to evaluate procedures for identifying and resolving credit balance and similar situations arising when beneficiaries have other insurance.
Key Initiatives for Physicians and Other Health Care Professionals
- "Incident to" Services- to examine the medical necessity, documentation, and quality of care for the services.
- Assignment Rules- to determine if providers are improperly "balance billing" beneficiaries.
- Business Relationships and Utilization Rates for MRI -to determine how financial relationships among physicians and others may affect utilization of MRI.
- Interventional Pain Management Payments -to research medical necessity, oversight, and payment for interventional pain management procedures.
- Utilization of Ultrasound -to examine geographic discrepancies in ultrasound utilization and charges.
- Density of Independent Diagnostic Testing Facilities ("IDTFs") -to examine service and billing patterns for IDTFs in geographic areas with large concentrations of IDTFs.
The 2008 Work Plan also includes initiatives for Home Health, Nursing Homes, Hospice, Durable Medical Equipment Suppliers, Medicare Part B Drug Reimbursement, Medicare Part D Administration, and more.
In addition to the specific initiatives outlined in the Work Plan, the OIG expressed continued concern about fraud and abuse and reaffirmed its commitment of significant resources to investigation of false claims and anti-kickback violations. To download the complete OIG 2008 Work Planclick here.