On January 31, 2014, the Office of Inspector General (“OIG”) for the Department of Health and Human Services released its Work Plan for Fiscal Year 2014. The Work Plan sets forth OIG’s audit and enforcement priorities for the coming year and, as such, is a must read for health care providers. The success of OIG’s efforts to root out health care fraud and overpayments from federal health care programs has been well documented. For FY 2013, OIG reported recoveries of more than $5.8 billion in audit and investigative receivables and the exclusion of over 3,214 individuals and entities from participation in Federal health care programs. The recoveries and exclusions arose, in large part, from topics covered in the OIG’s FY 2013 Work Plan.
OIG states in the 2014 Work Plan that will renew certain auditing initiatives originally set forth in the FY 2013 Work Plan. These initiatives include evaluating inpatient claims for mechanical ventilation, outlier payments, hospital participation in quality improvement projects, and graduate medical education payments. Continuing topics for physicians include noncompliance with assignment rules and place of service coding errors.
For FY 2014, the Work Plan includes several new areas of focus for Hospitals, which OIG will be examining for the first time. These include review of: (i) hospital E&M payments to determine whether clinic visits are billed at the new rates for new versus established patients; (ii) hospital privileging programs to ensure medical staff are properly evaluated; (iv) executive compensation to determine whether the required senior executive compensation benchmark is applied; (v) hospital billing for right heart catheterizations and heart biopsies; (vi) indirect medical education payments; and (vii) claims for bone marrow and stem cell procedures.
Additional new focus areas set forth in the 2014 Work Plan include reviewing Medicare claims for chiropractic services, payments for the setup of portable x-ray equipment, and claims for power mobility devices, nebulizer machines, and lower leg prosthetics.
Importantly, with respect to Medicare Part D, the 2014 Work Plan calls for OIG to conduct reviews of pharmacies’ Prescription Drug Event (PDE) data to verify compliance with federal requirements pertaining to prescription drug documentation. This auditing initiative follows a 2013 report by OIG that identified selected retail pharmacies as having questionable Part D Billing.
The above listed topics are a small sampling of the of areas OIG will be focusing on in the coming year when implementing its audit and enforcement programs. Therefore, the OIG Work Plan continues to be a must read for all administrators and compliance officers. The FY 2014 Work Plan is available for download on the OIG website here.