OIG 2011 Fiscal Year Work Plan

October 22, 2010, 02:39 PM

Each fiscal year the Department of Health and Human Services Office of Inspector General (“OIG”) releases a Work Plan that establishes a list of issues that OIG will focus on as priorities during the coming fiscal year. All health care entities are well advised to monitor and evaluate the Work Plan each year in order to understand which areas of its practice and which third-party reimbursement priority issues may be relevant to its practice for the coming fiscal year. OIG issued the 2011 fiscal year Work Plan on October 1, 2010. Among the issues that appear in the 2011 fiscal year Work Plan as priorities in the Medicare Parts A and B context are: (i) payments for high cost diagnostic testing, (ii) home health agency profitability trends, (iii) disproportionate share hospital payments, (iv) implementation of the hospital-acquired conditions policy, (v) impact of quality improvement initiatives in poorly performing nursing homes, (vi) the competitive bidding process and resultant pricing determinations for durable medical equipment (“DME”), and (vii) Medicare contractors’ administrative costs, including a review of the first level of the Medicare administrative appeals process and a review of the performance of the Medicare Recovery Audit Contractor (“RAC”) program in detecting and recovering overpayments. With regard to Medicare Part C, the Work Plan establishes as priorities, among others, the following: (i)Medicare Advantage (“MA”) plans’ chronic condition enrollment requirements, (ii) duplicate fee-for-service billings, and (iii) the financial impact of Medicare beneficiaries disenrolling from an MA plan on the federal healthcare program. For Part D, the priorities include, without limitation: (i) identifying deviations from usual benefit patterns, (ii) costs of high-volume prescription drugs to Part D plans as well as state Medicaid programs, and (iii) the reliability of Part D sponsors’ internal controls to combat fraud, waste and abuse. A copy of the entire fiscal year 2011 Work Plan can be downloaded at –Aaron J. Ambrose