OIG work plan a useful guide for quality
OIG work plan a useful guide for quality
Readmissions a continued focus
It must seem as though the number of important things to read and digest that come across a quality manager's desk is never-ending. But the 2013 Office of Inspector General (OIG) Work Plan should be at the top of your to-do list. It gives you a clear view of the things that are a concern for the OIG and with which you should ensure you are in compliance, says Mike McGinnis, a director and senior consultant with Warbird Consulting Partners in Shaver Lake, CA.
Of the 25 or so investigations related to hospitals that are listed in the plan, about half are new, he says. It is on those new items that you should focus your attention, McGinnis says.
Among those that are new is bundling. The OIG will look at whether bundling outpatient services delivered within two weeks of admission into a single DRG might result in some savings, McGinnis says. The current rule is for three days prior to hospital admission.
The OIG is also interested in looking at payments for cancelled surgeries. "They want to make sure that a subsequent real surgery takes place after the cancelled one."
If you are working with a quality improvement organization (QIO), this is of interest to the OIG, which wants to assess barriers those QIOs experience when working with hospitals.
Rules around mechanical ventilators, which require a minimum of 96 hours for a patient to trigger payment, is also on the agenda, he says. This might be a particular concern for quality staff since getting patients off ventilators as quickly as possible is important to patient safety.
For those working in long-term acute care hospitals, interrupted stays are something the OIG has its eye on, and if you have a home health agency in your hospital, McGinnis says you should be particularly aware of the OIG's interest in the face-to-face rule that requires physicians who certify that a Medicare beneficiary is eligible for home health actually see the patient in person. "Make sure that your agency understands the rules, follows them, and documents that they are followed," he advises.
McGinnis suggests that utilization review, the chief financial officer, and quality improvement departments take a look at the work plan separately and together. "The OIG does us a favor by publishing this. It tells us outright what the areas of concern are. You can look at your history, at your data, and see if you are compliant in these areas. If you are not, set up systems to ensure you become compliant or create projects that will lead to it," he says. "This should be your blueprint."
At Sierra View District Hospital in Porterville, CA, Donna Hefner, RN, MS, CPHRM, the executive director of risk, has already been through the work plan. She calls it a great reference.
"For me it's a great communication tool," Hefner says. "It helps me convey what is important to the appropriate people on the compliance committee to share with their respective staffs."
For any item that is marked as new, Hefner says she and her team will do an audit to see if the hospital is compliant. Already looking at the payments for cancelled surgeries issue, they are pulling charts and having representatives from all disciplines look at the information to see whether they need to make changes, corrections, or implement a quality improvement project. They will continue to focus on any emergent issue until compliance is 100% or there are three consecutive quarters at the required benchmark.
"I've found it to be one of the most useful reports over the years," Hefner says.
A complete copy of the work plan is available at https://oig.hhs.gov/reports-and-publications/archives/workplan/2013/Work-Plan-2013.pdf.
Sources
For more information, contact:
- Mike McGinnis, Director and Senior Consultant, Warbird Consulting Partners, Shaver Lake, CA. Telephone: (559) 788-6102. Email: [email protected]
- Donna Hefner, RN, MS, CPHRM, Executive Director of Risk, Sierra View District Hospital, Porterville, CA. Telephone: (559) 788-6193.
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