As we wrap up the 2014 calendar year, it is important to remember that the HHS Office of Inspector General is already well into their 2015 fiscal year. On October 31, 2014, the HHS Office of Inspector General (OIG) issued its fiscal year 2015 work plan. The plan in its entirety can be accessed on the OIG’s website via the following link:
https://oig.hhs.gov/reports-and-publications/workplan/index.asp.
Some items to be aware of include:
Reconciliation of Outlier Payments – Effective August 8, 2003, CMS implemented a change in methodology for determining outlier payments including a reconciliation process. This provision of the work plan deals with CMS’ performance of the outlier reconciliations in a timely manner.
Inpatient Admission Criteria – The so-called “two-midnight policy” has significant implications for hospital billing practices and the OIG previously identified “overpayments” related to short inpatient hospital stays. This review is to measure the impact of the new two-midnight policy.
Salaries Claimed in Cost Reports – The OIG plans to review employee compensation to determine the extent to which “remuneration for managerial, administrative, professional, and other services related to the operation of the facility and furnished in connection with patient care” is reasonable and should be subject to limits in the future.
Provider Based Status – While the impetus appears to be compliance with CMS’ criteria and billing and reimbursement implications, provider based status and recognition on the cost report also has implications for recognition as 340B covered entities.
Critical Access Hospitals and Swing Beds – This analysis will compare reimbursement for swing bed services in Critical Access Hospitals to traditional Skilled Nursing Facilities.
Billing Requirements – Prior OIG audits, investigations and inspections have identified certain non-compliant billing practices and the OIG will continue to use that information in its risk assessment and identification of future inpatient and outpatient billing audits.
Direct and Indirect Medical Education Payments – The Federal government contributes an excess of $11 billion per year to support graduate medical education therefore, reimbursement to providers for these activities will continue to be scrutinized by the OIG. The work plan includes testing for both potential duplicate and excessive payments under the current formula for reimbursing hospitals.
Hospital Wage Data – There is a new review associated with the controls over reporting wage data in the cost report. The OIG, in prior reviews, identified significant data reporting inaccuracies that resulted in policy changes and in addition to evaluating the reported data, the OIG will now review hospitals controls over the process.
CMS Contract Management – According to data quoted in the work plan, CMS obligated over $5 billion for a “variety of goods and services” and the OIG will continue to perform reviews in this area especially given vulnerabilities and weaknesses identified in prior reviews and other reports.
These are just a handful of the activities underway or planned by the OIG. Please review the full work plan to better assess items that are of particular relevance to your organization as well as items that you would like to tag for future updates. Southwest Consulting Associates (SCA) will keep you apprised as the OIG releases new updates and/or reports pertaining to the 2015 work plan.