On January 31, the OIG released its Work Plan for Fiscal year 2014 (which began on October 1, 2013). The Work Plan sets out the items the OIG will be reviewing during this fiscal year—and is a great tool to help Compliance Officers direct their compliance audits.
The work plan is about 100 pages, but don’t let that overwhelm you. It covers the entire health care industry, so the key is to find the pieces that apply to your organization. For example, the following items pertain to Nursing Homes:
Medicare Part A billing by SNFs.
The OIG is going to examine SNF billing practices and identify variation in billing among SNFs. This is a follow-up to a report issued by the OIG in 2012 in which it found 25% of SNF claims faulty in which it found that ¼ of all SNF claims from 2009 were erroneous, resulting in $1.5 billion in Medicare overpayments. The OIG found that SNFs increasingly billed for the highest level of therapy even though beneficiary characteristics had not changed.
SNFs can prepare for this review by using their PEPPER reports to determine whether their organization is an outlier in high-risk areas of therapy billing.
Questionable billing patterns for Part B services during nursing home stays
The OIG is going to identify questionable billing patterns, focusing on several categories of services, including foot care. The OIG was told by Congress to monitor Part B billing for abuse during non-Part A stays. The government is concerned about Part B services provided to nursing home residents during stays that are not paid under Part A. For example—stays during which benefits are exhausted or the 3-day prior-inpatient-stay requirement is not met.
This is an opportunity for nursing homes to do a similar review of their own billing.
State agency verification of deficiency corrections
The OIG is going to evaluate whether State survey agencies verified corrective action plans for deficiencies identified during nursing home recertification surveys. A prior OIG review found that one State survey agency—and we don’t know which one—failed to verify that nursing homes corrected survey deficiencies.
This might not sound relevant for nursing homes—and it might not be as important as the first two, where SNF billing is under scrutiny. But we might see an increase in review by the State survey agency. This is a reminder to make sure that corrective action plans are complete and carried through.
Hospitalizations of nursing home residents for manageable and preventable conditions
In 2013, the OIG found that 25% of Medicare beneficiaries were hospitalized in Fiscal Year 2011. The OIG is going to determine the extent to which Medicare beneficiaries in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable. If this looks familiar, it is because this is not new for fiscal year 2014—it is a continuation of prior work, that the OIG expects to wrap up this year.
As we all know, the OIG is concerned about hospitalizations of nursing home residents because they cost Medicare a lot of money, and sometimes raise quality of care questions.
Now is the time to make sure that your hospitalizations are being managed in your quality assurance program.