2016 OIG Work Plan, here’s another reason to pay attention


If you’ve read my recent post, 2016 OIG Work Plan-Nursing Homes, you know that the OIG has introduced a new project that seeks to examine the SNF prospective payment system. (If you haven’t read the blog, stop here and read it. Don’t worry, we’ll wait for you.) The US Department of Health and Human Services just recently released their Fiscal Year 2015 Agency Financial Report (I’ve included a link to the report just in case you would like to wade through the 274 pages) and it contains further reasons for LTC providers to take notice and action on the 2016 OIG work plan.

How does it relate to the 2016 OIG work plan & what’s with the report?

Here are some tidbits that show the results of OIG’s enforcement activities and should give you an understanding as to why they will be committed to the 2016 OIG work plan:

  • The Healthcare Fraud and Abuse Program returned $7.70 for every $1 invested in the program. (That’s a healthy return that would make any business envious!)
  • In FY 2014, OIG audits and investigations resulted in expected recoveries of $4.9 billion in improperly spent federal health care dollars.
  • As a result of OIG legislative, regulatory and administrative actions, OIG reports estimated savings of more than $15 billion. (Yep, that’s billions with a “b”!)

And a couple more points to chew on:

  • The improper payment rate for SNF’s rose from 6.94% to 11.04%, a substantial increase of nearly 60% in just one year.
  • The HHS report identified the primary cause of this dramatic rise was insufficient documentation, which they indicated was a “common” problem among SNF providers.

The 2016 OIG work plan, is it any wonder why there’s a new project!

As I mentioned earlier, the 2016 OIG work plan includes a new project that calls for the OIG to review the SNF prospective payment system and more specifically, the documentation which supports SNF claims. LTC providers need to:

  1. Make sure that your compliance program is active, dynamic and individualized to your organization/facility. (I can’t emphasize this enough.)
  2. As a part of your audit activities, insure that you are examining the quality and depth of your documentation to assure yourself that it fully supports your claims.

The good news-if you’re doing the above, good job and carry on. And if you’re not…well, the bad news is that the OIG is not going away and is it really worth the risk getting in their cross hairs?

When you need proven expertise and performance

Craig Fukushima, NHA, MBA

Mr. Craig T. Fukushima’s health care experience spans more than 35 years with special expertise in the long term care sector, including implementation of innovative health care projects in domestic and international locations.