The 2016 OIG Work Plan was released on November 2, 2015. The 2016 version weighs in at a slimmer 80 pages versus its more hefty 2015 sibling which was 90 pages. (The trees are happy!) If you would like an excellent overview of the entire work plan, please see our post entitled “The 2016 OIG Work Plan-An Introduction”. Also, if you’re exceptionally interested in looking through the entire document, feel free to download the complete 2016 OIG Work Plan here..
So you’re a nursing home provider and want to know what’s in store for 2016? Let’s take a look!
What’s in the 2016 OIG Work Plan-Nursing Homes?
In comparison to the 2015 work plan, the 2016 OIG work plan as it pertains to nursing home providers is a slimmed down version in terms of projects. In 2015, the OIG had five projects, none of which were new projects. However, in 2016, the OIG has only two projects and of the two, only one is new. Let’s check out the 2016 projects:
National Background Check Program for long term care employees
This project is a carry over from 2015 OIG work plan. The OIG will continue to review the procedures implemented by States that require long term care facilities and providers to conduct background checks on prospective long term care employees and providers who have direct access to patients.
What should providers do? Check with your state agency and verify that you are following their procedures for background checks for your applicable employees. Your quality assurance program should include a review of your adherence to those procedures. (By the way, if you read our blog last year and took our guidance and implemented it, good for you, you don’t have to do anything new!)
Skilled Nursing Facility prospective payment requirements
This is a NEW project in the OIG Work Plan 2016 and should really get your attention. In prior reviews, the OIG has found that Medicare payments for therapy delivered in SNF’s greatly exceeded the cost. Further, the OIG has found that providers have billed for the highest level of therapy even though the characteristics of the patient did not change. The OIG intends on reviewing various aspects of the prospective payment system and insuring that SNF claims were paid in accordance with all federal laws and regulations. This will include a review of documentation to make sure that SNF care was reasonable and necessary.
What should providers do? Your compliance audit should include a review of documentation to insure that it contains the following:
- a physician order at the time of admission
- a comprehensive assessment
- a comprehensive plan of care prepared by the interdisciplinary team that includes the attending physician, RN, and other appropriate staff
One more item for nursing homes in the OIG Work Plan 2016
While not listed in the nursing home section, there is one “revised” project in the 2016 OIG work plan that does pertain to nursing home providers.
Hospice general inpatient care
OIG will not only review the medical necessity of general inpatient hospice claims but they will also review the content of election statements for hospice beneficiaries who received general inpatient care.
Some final thoughts on the 2016 OIG Work Plan-Nursing Homes
For those readers who have followed our blogs including our thoughts on your compliance program (AND took our advice!), your pulse rate probably didn’t quicken much as you read about the OIG work plan for 2016. If, on the other hand, your hands started to sweat and you began to feel light headed, perhaps it’s time to re-visit that compliance program of yours and add some bulk to it. Not to worry though, as I said in last year’s blog, an ounce of prevention is worth a pound of cure!