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OIG Work Plan for FY 2010 Has Been Released

The OIG released its Work Plan for the 2010 fiscal year (FY) this week, to be effective beginning October 2009. The OIG’s Work Plan “describes the specific audits and evaluations that [the OIG has] underway or plan[s] to initiate in the FY ahead….The Work Plan also provides focus areas for [the OIG’s] investigative, enforcement, and compliance activities.” The OIG Work Plan includes:
– Reviewing Part B payments for services rendered in home health episodes;
– Reviewing claims submitted by home health agencies to determine the accuracy of the billing codes and to identify miscoding patterns;
– Determining whether payment methods for home health agencies should be adjusted by reviewing the home health agency cost data and profitability trends;
– Reviewing CMS’ role and procedure in ensuring HHA submits accurate OASIS data;
– Reviewing hospice claims to see the trends in hospice utilization;
– Examining the payment systems and payment rates for ambulatory surgery centers;
– Determining whether Medicare-enrolled IDTFs satisfy the Medicare enrollment standards;
– Determining what kinds of physician self-referrals are permissible to DME suppliers in which the physician holds an ownership interest in that supplier;
– Reviewing DME claims submitted under Medicare Part B and determining whether those claims were submitted pursuant to Medicare’s requirements;
– Verifying that CMS has implemented the OIG recommendations from August 2008 regarding the medical review of claims for the CERT program DME review for the fiscal year of 2006;
– Reviewing the DME Medicare fee schedule and determining whether the DME items that were originally classified are properly classified according to current, updated standards and payment methodologies;
– Reviewing CMS’ oversight of the RAC program and CMS’ guidance and training pertaining RACs and appropriately reporting potential instances of fraud;
– Reviewing hospice beneficiaries’ drug claims under Medicare Parts A and D and identifying controls to prevent duplicate reimbursement under both Parts;
– Reviewing home health agency claims to determine if providers have met the eligibility criteria for home health services;
– Investigating instances of false claims;
– Investigating businesses that have allegedly violated the Federal Anti-Kickback Statute;
– Examining CMS’ oversight in the breach notification requirements and CMS’ steps in preventing medical identity theft;
– Reviewing incentive payments for adopting electronic health records and CMS’ safeguards against payments made in error; and – Assessing the adequacy of the IT security controls in place pursuant to the health information technology standards enumerated in the Recovery Act.

For more information, please contact Abby Pendleton, Esq., Jessica L. Gustafson, Esq., Robert S. Iwrey, Esq., Carey F. Kalmowitz, Esq. or Adrienne Dresevic, Esq. at (248) 996-8510 or visit The HLP website.

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