Recently, the Department of Health and Human Services Office of the Inspector General (the OIG) released its work plan for 2015. The work plan provides stakeholders with a road map to the OIG’s activities in the coming year as they relate to its enforcement priorities and issues it will review and evaluate during the year. This post is one in a series that will outline the OIG’s activities, in 2015, for a specific industry sector – skilled nursing facilities (SNF).

Medicare Part A Billing

The OIG remains concerned about the high levels of therapy services being provided in the SNF setting despite its understanding that beneficiary characteristics have remained unchanged in FYs 2011 to 2013. It is going to continue to evaluate how CMS changes have and will effect these billing patterns.

Part B Services During Nursing Home Stays

The OIG is going to evaluate what it believes are questionable billing patterns associated with nursing homes and Medicare providers for Part B services provided to nursing home residents during non-Part A stays. A series of studies will examine several broad categories of services, such as foot care.

State Agency Verification of Deficiency Corrections

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. Continuing on that investigative track, the OIG will take a broader look at whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys.

Program for National Background Checks for LTC Employees

The OIG is going to review the procedures implemented by participating States for long-term-care facilities or providers to conduct background checks on prospective employees and providers who would have direct access to patients and determine the costs of conducting background checks. Section 6201 of The Affordable Care Act (ACA) required the Secretary of Health and Human Services to carry out a nationwide program for States to conduct national and State background checks for prospective direct patient access employees of nursing facilities and other long-term-care providers.

Preventable Hospitalizations of Nursing Home Residents

This is an issue that has been studied widely and will likely lead to a “never event” type penalty system for SNF providers. The OIG is, again, looking at the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting.