OIG issues Work Plan for the next year

The Office of Inspector General (OIG) at the Department of Health & Human Services (HHS) has issued its Work Plan for 2012, indicating what areas will be of most interest for investigations and enforcement action. Much of the work plan involves a greater focus on the new issues raised by the changes introduced by the Patient Protection and Affordable Care Act (PPACA)

OIG's Work Plan is aspirational and, as a result, many projects are carried over from year-to-year as priorities shift and projects planned in the beginning of the fiscal year are set aside, according to an analysis by the law firm of Foley & Lardner, with offices across the country. The fact that a project has not been carried over does not suggest that OIG is no longer interested in that area, the law firm explains. (The work plan can be found at http://tinyurl.com/3aunow5.)

There are a significant number of new projects related to state Medicaid programs, as well as an emphasis on fraud and abuse reviews, the firm notes. Medicare Parts C and D also received an increased share of OIG's attention regarding new projects.

The 2012 Work Plan identifies 23 projects targeting hospitals. Of these 23, six are new projects. OIG will continue reviews related to hospital reporting of adverse events and present on admission conditions, as well as outlier payments and reporting of quality data. Foley & Lardner provides this overview of some of the major projects from the 2012 Work Plan:

• Accuracy of Present-on-Admission Indicators Submitted on Medicare Claims (OEI).

• OIG will review the accuracy of present-on-admission (POA) indicators submitted on inpatient hospital claims. CMS requires hospitals to submit POA indicators with each diagnosis code on Medicare hospital inpatient claims. Under PPACA, hospitals with high rates of hospital-acquired conditions receive reduced payments, so POA indicators are necessary to implement the new requirement.

• Medicare Inpatient and Outpatient Payments to Acute Care Hospitals (OAS).

• OIG will review hospital Medicare payments to determine hospital compliance with selected billing requirements and to recommend recovery of overpayments for providers that routinely submit improper claims. OIG will review high- and low-compliance risk hospitals and will compare the compliance practices of the two groups.

• Acute-Care Hospital Inpatient Transfers to Inpatient Hospice Care (OAS).

• OIG will review Medicare claims for inpatient stays for which the beneficiary was transferred to hospice care. For such claims, OIG will examine the financial or common ownership relationship between the acute-care hospital and the hospice provider. OIG also will examine how Medicare treats reimbursement for similar transfers from the acute care setting to other settings.

• Medicare Outpatient Dental Claims (OAS).

• OIG will review hospital outpatient payments for dental services to determine whether payments for dental services were made in accordance with Medicare requirements. Generally, Medicare excludes dental services, but OIG audits revealed that providers were receiving Medicare reimbursement for noncovered dental services, which resulted in significant overpayments.

• Inpatient Rehabilitation Facilities (OEI).

• OIG will examine the appropriateness of admissions to inpatient rehabilitation facilities (IRFs). IRFs provide rehabilitation services for patients who require a hospital-level of care to improve their ability to function. OIG will review the level of therapy and how much concurrent group therapy is provided.