The United States Department of Health and Human Services Office of Inspector General (“HHS-OIG”) has released its Work Plan for Fiscal Year 2016. This plan summarizes new and continuing areas of review and activities that HHS-OIG plans to pursue as well as describing its primary objectives. The newest additions to the work plan are:
• Medical device credits for replaced medical devices • Medicare payments during Medicare Severity Diagnosis Related Groups (MS-DRG) payment window • Content Management System (CMS) validation of hospital-submitted quality reporting data • Skilled nursing facility prospective payment system requirements • Orthotic braces-reasonableness of Medicare payments compared to amounts paid by other payers • Osteogenesis stimulators-lump-sum purchase versus rental • Orthotic braces-supplier compliance with payment requirements • Increased billing for ventilators • Ambulatory surgical centers-quality oversight • Physicians-referring/ordering Medicare services and supplies • Anesthesia services-non covered services • Physician home visits-reasonableness of services • Prolonged (E & M) services-reasonableness of services • Histocompatibility laboratories-supplier compliance with payment requirements • Accountable Care Organizations: Strategies and Promising Practices • Medicare payments for unlawfully present beneficiaries in the United States-mandated review • Medicare payments for incarcerated beneficiaries-mandated review • Content Management System (CMS) management of ICD-10 implementation • Medicare Advantage organization practices in Puerto Rico • Medicare Part D beneficiaries’ exposure to inappropriate drug pairs • Medicare Part D Eligibility Verification transactions • Part D Pharmacy Enrollment • Increase in prices for brand-name drugs under Part D • Specialty drug pricing and reimbursement in Medicaid • Express Lane Eligibility • State agency verification of deficiency corrections • Medical loss ratio-recoveries of MCO rebates from profit-limiting arrangements • Review of States’ methodologies for assigning Managed Care organization payments to different Medicaid FMAPs • Managed long-term-care reimbursements • Center for Disease Control (CDC)-oversight of the Select Agent Program • Controls over networked medical devices at hospitals • Food and Drug Administration (FDA)-tobacco establishment compliance with the Family Smoking Prevention and Tobacco Control Act • Health Resources and Services Administration (HRSA)-compliance with Maternal, Infant, and Early Childhood Home Visiting (MIECHV) Requirements • IHS-change card program review • NIH-controls over subcontracting of NIH grant and contract work • Controls over the preparation and receipt of select agent shipments • Review of Office for Human Research Protections compliance evaluations to ensure human subject protection • Foster Care-States’ protocols for the use and monitoring of psychotropic medications for children in foster care • States’ implementation of guardian ad litem requirements • Consumer Operated and Oriented Plan Loan Program-CO-OP compliance with requirements and CMS monitoring activities • Allowability of contract expenditures • Rollup of State-based marketplace eligibility determination audits and Content Management System (CMS) oversight • Health Resources and Services Administration (HRSA)-compliance with Maternal, Infant, and Early Childhood Home Visiting (MIECHV) requirements
The U.S. Department of Health and Human Services Office of Inspector General has released their Work Plan for Fiscal Year 2016
The HHS-OIG expects significant recoveries in audit receivables, investigative receivables and non-HHS investigative receivables resulting from their Work Plan, as well as tremendous savings in legislative, regulatory, and/or administrative actions.
Robert S. Iwrey, Esq., a founding partner of The Health Law Partners, P.C., practices in all areas of healthcare law and devotes a substantial portion of his practice assisting clients in compliance, third party payor audits, government investigations, state licensing and DEA registrations. For more information regarding this article, please contact Robert S. Iwrey, Esq. at (248) 996-8510 or (212) 734-0128 or firstname.lastname@example.org.