OIG Work Plan Updates: September 2018

The September 2018 additions to the HHS OIG Work Plan were limited to two, both somewhat esoteric and unlikely to impact the majority of healthcare providers.

  1. Review of Opioid Use in Indian Health Service: Consistent with prior OIG work plan items regarding Medicare Part D and Medicaid, this work plan addition will seek to “determine the extent to which beneficiaries are receiving extreme amounts of opioids through Indian Health Service (IHS), as well as IHS-employed prescribers and IHS-run pharmacies that have questionable prescribing or dispensing patterns. This review will also determine how IHS prevents and detects opioid misuse or abuse, as well as how it enforces its opioid-related policies.”

  2. Follow-up Review of Head Start Grantee: Pertains to one specific entity, not applicable to wider constituencies at this time.

New additions to the work plan of import added in August 2018 during the height of vacation season that slipped by VantagePoint scrutiny included:

  1. Physician Billing for Critical Care Evaluation & Management Services: As an exclusively time-based service, physicians must clearly document the time spent evaluating, providing direct care and managing the patient in order to qualify for reimbursement of a critical care E/M visit, per the OIG “This review will determine whether Medicare payments for critical care are appropriate and paid in accordance with Medicare requirements.”

  2. Hospitals' Compliance with Medicare's Transfer Policy With the Resumption of Home Health Services and the Use of Condition Codes: Hospitals transferring a patient to another facility or home health service are subject to a reduction in DRG payment. The OIG seeks to “determine whether Medicare appropriately paid hospitals' inpatient claims subject to the postacute care transfer policy when (1) patients resumed home health services after discharge or (2) hospitals applied condition codes to claims to receive a full DRG payment.”

State of Maryland fails OIG security audit, Medicaid data at risk

OIG performed a vulnerability assessment scan to determine if there were existing vulnerabilities on the MMIS (Medicaid Management Information System) network, devices, websites and database. And while OIG officials found the state adopted a security program for the system, there were “significant system vulnerabilities.”

Officials did not disclose details of the vulnerabilities found, but said that they were significant enough to "have allowed unauthorized access and exposed Medicaid data and the disruption of critical Medicaid operations.”

The State said there was no evidence of a breach or unauthorized access. And, while a security program was in place, the control were not sufficient to keep the systems protected. Recommendations were made to the state to update the security program and systems to meet federal requirements. 

Updates to the OIG Work Plan: August 2018 Highlights

VantagePoint monitors the monthly updates to the Office of Inspector General (OIG) work plan. The month of August is proving to be somewhat light in comparison to July with only one item posted to the Recently Updated items page (linked to the title of this post).

The August 2018 sole updated relates to the OIG's planned review focusing on the "care and well-being of all children residing in ORR-funded facilities, including the subset of children who were separated and deemed ineligible for reunification." The OIG also plans to focus on the effectiveness of the Office of Refuge Resettlement efforts to unify separated children with their parents.

Updates to the OIG Work Plan: July 2018 Highlights

Back in June 2017, the Office of the Inspector General (OIG) announced they would begin posting monthly updates to their work plan. Keeping tabs on the OIG Work Plan is a best practice for compliance and revenue cycle professionals. The items may at times appear esoteric, but the appearance of a new initiative is akin to the proverbial canary in a coal mine.

The additions posted in July 2018 include:

  • New review of CMS payment policy in respect to 3-D radiation therapy planning services. Medicare policy prohibits payments for separately billed radiation planning services when the services are billed on a different date of service. The review by the OIG is designed to determine if the prohibition had been extended to 3-D radiation therapy.
  • The HHS OIG will perform a series of audits to assess cybersecurity vulnerabilities at HHS.
  • OIG assess the effectiveness of the Health Resources and Services Administration (HRSA) oversight of the Access Increases in Mental Health and Substance Abuse Services (AIMS) grants.
  • OIG working on a report discussing the describing the impact  of additional Medicare outlier payments in balancing the reduction in DRG, DSH, and IME payments of transfer claims. This is one for hospital revenue cycle compliance folks to watch!
  • Another CMS focused audit by the OIG was added in respect to post-operative services provided in the global surgery payment period and whether global surgery fees reflected the actual number of post-operative services provided.
  • The final item added in July is a series of audits of the Substance Abuse and Mental Health Services Administration's process and oversight in respect to SAMHSA-approved accrediting bodies that have accredited Opioid Treatment Programs (OTP).