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A Better Partnership


Sep 2006
September 01, 2006

2007 Annual Work Plan Published

The Office of Inspector General, Health and Human Services, has released its "Work Plan" for fiscal year 2007. The Work Plan, which is published annually by the OIG, identifies areas of vulnerability in HHS programs and activities. The plan sets forth the areas in which the OIG will focus its enforcement and investigative resources in the upcoming year. The plan is a useful resource tool for entities seeking to focus their compliance initiatives in the areas identified by the OIG as potentially being problematic. This year, the OIG has identified over 250 programs or initiatives that could impact health care entities, a substantial increase from previous work plans. This year's highlights include:

  • Hospital Capital Payments: The OIG will examine Medicare inpatient capital payments, to determine whether they are being appropriately used for their intended purpose.

  • Payments for Observation Services Versus Inpatient Admission for Dialysis Services: The OIG will examine inpatient admissions for dialysis services to determine medical necessity and to confirm that physician orders calling for admission for observation status were properly followed.

  • Inpatient Hospital Payments for New Technologies: The OIG will examine the costs associated with new devices and technologies to determine whether the reimbursement is appropriate.

  • Long-Term Care Hospital Admissions: The OIG will examine whether LTCHs receive most of their patients from a single acute care hospital, which would effectively render them a unit of the Hospital. This is problematic because of differences in the reimbursement schedule.

  • Outpatient Outlier and Other Charge-Related Issues: In an ongoing initiative, the OIG will continue to examine whether outlier payments made to hospital outpatient departments were in accordance with federal law.

  • Outpatient Department Payments: In a previously announced initiative, the OIG will continue to review the appropriateness of payments made to outpatient departments for multiple procedures, repeat procedures and global surgeries.

  • DRG Coding: DRG coding remains a volatile area. The OIG will continue to examine medical facilities which exhibit high or unusual patterns for selected DRGs.

  • Inappropriate Payments for Diagnostic X-rays in Hospital Emergency Departments: In 2004, 2.5 million X-rays were performed in Medicare certified EDs. Some facilities are inappropriately billing for a separate interpretation; a practice which the OIG intends to discourage.

  • SNF Rehabilitation and Infusion Therapy Services: The OIG intends to analyze whether rehabilitation and infusion therapy services provided by SNFs are medically necessary, adequately supported and actually provided as ordered.

  • Imaging and Lab Services in Nursing Homes: The OIG will examine the extent and nature of medically unnecessary or "up-coded" lab services for SNF residents.

  • Hospice Payments: In separate initiatives, the OIG intends to examine care plans for terminally ill patients and the relationships between hospice staff and SNFs. A recent survey by OIG revealed that nursing home hospice patients received 46% fewer nursing and aide services from hospice staff than hospice patients living at home. This has raised the issue of whether HHS is being "doubled billed" for certain hospice services.

  • PT and OT services: In another ongoing initiative, the OIG will continue to review OT and PT services to insure that they were medically necessary and properly documented.

As with last year's plan, Part D administration and Part B drug reimbursement continues to be an area of focus for the OIG.

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