The Office of Inspector General Releases Its Fiscal Year 2015 Work Plan

by John W. Kaveney

On November 1, 2014, the United States Department of Health and Human Services, Office of Inspector General (OIG), published its Fiscal Year 2015 Work Plan (available here). For most providers subject to the OIG’s reviews, the areas of focus remained the same with the core categories of review being (1) policies and procedures; (2) billing and payments and (3) quality of care and safety.

Hospital reviews of billing and payment practices included a new area of focus: hospital wage data used to calculate Medicare payments. According to the OIG, past work in the area of wage indexes revealed hundreds of millions of dollars in incorrectly reported wage data. This resulted in CMS changing its policy with regard to how hospitals report deferred compensation costs. The OIG will be placing a renewed emphasis this year on the validity and accuracy of the wage data.

Another new area of hospital review in the quality of care and safety category will include: long-term care hospitals – adverse events in post-acute care for Medicare beneficiaries. The OIG will be estimating the national incidence of adverse and temporary harm events for Medicare beneficiaries receiving care in long-term-care hospitals. From those estimations, the OIG will be identifying factors contributing to these events and attempting to determine whether they were preventable and thereby estimating the associated costs to Medicare.

The OIG introduced a few other new areas of focus for fiscal year 2015. For independent clinical laboratories, the OIG will be attempting to determine laboratory compliance with selected billing requirements believed to be at high risk for overpayments. Accountable Care Organizations are also being reviewed with the OIG indicating it will be conducting a risk assessment of the Pioneer Accountable Care Organization Model to determine whether there are appropriate internal controls over the administration of these new health care delivery systems.

State Medicaid programs will also see a few new areas of focus under the OIG’s 2015 Work Plan. State collection of rebates for drugs dispensed by Medicaid MCOs will be one new area of focus with the OIG reviewing whether drug utilization is being properly reported to the State and whether the States are then appropriately collecting the rebates from the manufacturers. Another area of focus will be transfers of Medicaid patients from group homes or nursing facilities to hospital emergency departments. The OIG will be determining whether high occurrences of transfers is a sign of poor quality of care. The OIG Work Plan notes that this area is one of interest to Congress as well. Finally, the OIG has identified concerns with MCO’s paying for services after a Medicaid beneficiary has passed away or for beneficiaries later determined to have been ineligible for Medicaid at the time of services.

These are just a few of the new areas of focus identified by the OIG. The OIG’s Fiscal Year 2015 Work Plan provides a complete list of all new areas of focus along with all areas of past review that remain part of the OIG’s target work.