The Office of the Inspector General (OIG) released its 2012 Work Plan the other day, as they do every year at about this time. This is the annual publication that contains descriptions of new and ongoing reviews and activities that OIG plans to pursue with respect to HHS programs and operations during the next 12 months and beyond.
Traditionally, in the opening pages of the OIG Work Plan there’s a list of recent accomplishments based on their investigations. In this edition they cite, among other things, the following:
- $3.8 billion in court ordered civil settlements that resulted from cases developed by OIG investigators;
- $1.1 billion in audit receivables that were agreed to be pursued by HHS program managers as a result of OIG audit disallowance recommendations;
- a ratio of $16.7 to $1 expected return on investment measuring the efficiency of OIG’s health care oversight efforts.
With those kinds of results, and especially with an almost seventeen-fold annual return on investment (who wouldn’t like that?), it suffices to say that the the OIG’s auditing efforts will continue to get considerable support from the Federal Government. It also means that anyone whose business is connected to the healthcare industry would do well to familiarize themselves with those areas that the OIG says they will be focusing on.
Use the OIG Work Plan as a resource for your healthcare compliance program
Thankfully, unlike some government documents, the OIG Work Plan, though long (165 pages this year) is fairly easy to follow. It’s broken up into seven major categories, and from there it’s organized into smaller categories or industry sectors, and finally it provides a brief description of each review item that covers what’s being reviewed and a reference to the regulations that govern the reviewed item. There are a total of 349 current and planned reviews listed in this year’s document, 99 of which are new items to be focused on.
The OIG Work Plan isn’t intended to be intimidating. Rather, it’s both an excellent resource for a proactive healthcare compliance plan, and an important part of decreasing waste and fraud in our federally funded healthcare programs. Consequently, I strongly recommended that you download a copy of the OIG Work Plan each and every year so that you’re able to keep informed on areas of review that may involve your own heatlhcare business. I also recommend that each of those areas of OIG review that do affect your business be incorporated into your own compliance plan for internal review and auditing.
A few samples from the OIG Work Plan for 2012
The following are my comments on just a few excerpts from the OIG Work Plan for 2012. They’re intended to provide a sample of what’s included in this valuable publication from the Office of the Inspector General.
Physicians: Impact of Opting Out of Medicare (New)
This review is actually looking at two separate, but related issues. The first issue is focused on determining whether physicians who have opted out of Medicare are still submitting claims to Medicare. The second issue is actually studying whether specific areas of the country have seen higher numbers of physicians opting out of Medicare, and what the potential impact is on beneficiaries.
Evaluation and Management Services: Trends in Coding of Claims
This current review will continue to focus on Evaluation and Management (E&M) claims from the period of 2000 through 2009, and will further attempt to identify providers that exhibited questionable billing for E&M services in 2009. The OIG points out that E&M related Medicare payments in 2009 totaled over $32 billion, and represented 19% of all Medicare Part B Payments. This review item, which is largely focused on E&M coding and documentation practices, is clearly a case of spending auditing resources on those areas where there’s the most activity, a practice that makes perfect sense for any kind of hunting.
In-Patient Rehabilitation Facilities (New)
This is a new review in which In-Patient Rehabilitation Facilities (IRF) are to be examined to determine the appropriateness of their admissions. The focus will be on the level of therapy being provided, and how much concurrent and group therapy is being provided in these settings. An IRF can be a free standing rehabilitation hospital, or a rehabilitation unit in an acute care hospital. Patients admitted to IRF’s must be able to tolerate three hours of intense rehabilitation services per day.
More on the 2012 OIG Work Plan to come …
In future posts we’ll delve into some additional areas of particular interest in the coming year’s plan. We’ll help explain some of the areas being audited, and provide you with suggestions about how you can use this information to make sure that your own organization remains proactive and compliant. So bookmark us, and check back often … or better yet, subscribe to our feed!