As compliance officers prepare their work plans for 2017, it is worth remembering those matters of current interest to the HHS Office of Inspector General (OIG) that are reflected in its 2017 Work Plan. The OIG’s plan outlines new and ongoing reviews of HHS programs and operations and timeframes for completion. The OIG reviews various providers, including hospitals, nursing homes, and home health services. Items in the Work Plan of particular significance include the following:
- incorrect medical assistance days claimed by hospitals (addressing risk of overpayment under the Medicare disproportionate share hospital payments);
- case review of inpatient rehabilitation hospital patients, not suited for intensive therapy;
- inpatient psychiatric facility outlier payments;
- Medicare costs associated with defective medical devices;
- unreported incidents of abuse and neglect in skilled nursing facilities;
- skilled nursing facility reimbursement;
- review of hospice compliance with Medicare requirements;
- Medicare payments for transitional and chronic care management;
- Medicare Payments for Service Dates After Individuals’ Date of Death;
- Centers for Medicare & Medicaid Services (CMS)’ implementation of the Quality Payment Program;
- Medicare Part D rebates for drugs dispensed by 340B pharmacies;
- Medicaid overpayment reporting and collections; and
- CMS oversight and issuer compliance in ensuring data integrity for the Affordable Care Act (ACA) Risk Adjustment Program.
Tom Herrmann, J.D., a retired OIG executive who was intimately involved in past OIG Work Plan development, advises compliance officers to closely review the entire OIG Work Plan, as it telegraphs issues that have come to the OIG’s attention as potential problem areas warranting close examination. The results of such reviews often lead to proposed legal and regulatory changes. They also may trigger additional audits, evaluations, and investigations. Examining the Work Plan items that may relate to their organizations in detail is an opportunity for compliance officers to get ahead of the power curve, rather than behind it. The fact is that one of the purposes of publishing the OIG Work Plan is to encourage health care entities to engage in such self-examination and program improvement.
Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.
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Copyright © 2016 Strategic Management Services, LLC. Published with permission.