In an effort to assist our clients and friends with reviewing the OIG Work Plan for Fiscal Year 2015, we will be publishing a series of articles focusing on different aspects of the Work Plan. In this first article of the Series, we focus on the new reviews and projects that have been added to the OIG’s portfolio.

The focus areas for enforcement priorities and issues relative to skilled nursing facilities (SNF) identified in the Department of Health & Human Services’ Office of Inspector General’s (OIG) 2015 Work Plan (2015 Plan) is very similar to the OIG 2014 Work Plan (2014 Plan). The 2014 Plan focused on: (1) Medicare Part A Billing; (2) Part B Services during Nursing Home Stays; (3) State Agency Verifications of Deficiency Corrections; (4) a Program for Nation Background Checks for Long-Term Care Employees; and (5) Preventable Hospitalizations of Nursing Home Residents. The 2015 Plan identified the same five areas for a second consecutive year. OIG will again focus on the following: 

Medicare Part A Billing: OIG will focus on the substantial changes previously issued by CMS regarding how SNFs bill for services provided during Medicare Part A stays. More specifically, OIG will continue to emphasize the billing changes for these services that were introduced during FYs 2011 to 2013. OIG seeks to address SNFs billing for the highest level of therapy even though beneficiary characteristics remained largely unchanged.

Part B Services during Nursing Home Stays: OIG will maintain its theme of reducing inappropriate billing by continuing efforts to reduce the billing and reimbursement for unnecessary and excessive Part B services (i.e., foot care) to residents during stays not paid under Part A.

State Agency Verifications of Deficiency Corrections: CMS requires that state survey agencies verify the Plan of Correction and correction of identified deficiencies through onsite review or by obtaining evidence of correction. In recent years, the OIG has found a trend by state survey agencies of failing to conduct the required follow-up confirmation. Accordingly, the OIG will continue to ensure that the agencies conduct such follow up.

Program for Nation Background Checks for Long-Term Care Employees: Under the Patient Protection and Affordable Care Act, CMS is required to carry out a nationwide program for states to conduct national and state background checks for prospective SNF employees with direct access to SNF residents, and CMS is also required to submit a report to Congress evaluating the implemented program. OIG will continue to review the procedures implemented by states for SNF providers to conduct proper background checks and the costs associated with the same.

Preventable Hospitalizations of Nursing Home Residents: OIG will resume efforts to determine the extent to which SNF residents are hospitalized as a result of a condition thought to be manageable or preventable.