HHS OIG Report Highlights 25 Unimplemented Recommendations to Reduce FWA

The Office of Inspector General (OIG) within the U.S. Department of Health and Human Services (HHS) recently released their list of top unimplemented recommendations. The HHS OIG recommendations are based on the department’s observations culled from conducting their auditing and enforcement function to protect the integrity of government health care programs.

Unimplemented HHS OIG recommendations that if implemented by CMS would most directly impact healthcare provider financial, operations, and compliance programs includes:

  • The HHS OIG has found persistent confusion exists regarding time counted toward 3-day hospital admission requirement among SNF providers. CMS should reanalyze the potential impacts of counting time spent as an outpatient toward the 3-night requirement for SNF Medicare coverage.

  • Based on audit recoveries, the HHS OIG recommends TCMS should implement the statutory requirement for $50,000 surety bonds for Home Health Agencies enrolled as Medicare providers and consider doing the same for other provider types.

  • The HHS OIG has observed there are limited options to sanction hospice providers with serious deficiencies and recommends CMS should seek statutory authority to establish additional remedies for hospices with poor performance.

  • Due to payment incentives that have resulted in admissions that did not meet medical necessity requirements, the HHS OIG recommends CMS should reevaluate the IRF payment system, which could include seeking legislative authority to make any changes necessary to more closely align IRF payment rates and costs.