On Oct. 2, 2012, the U.S. Department of Health and Human Services’ (HHS) Office of Inspector General (OIG) released its Work Plan for fiscal year 2013. Each year, this is of keen interest to anyone who deals with the Medicare or Medicaid programs, as it provides a sneak peek of OIG’s enforcement priorities and key areas of concern. Many investors and lenders in the industry also look to the Work Plan for guidance in understanding whether certain widespread practices are being viewed negatively by OIG.
The Work Plan summarizes OIG’s upcoming audit and enforcement priorities with respect to HHS programs. The Work Plan contains summaries of more than 240 Medicare and Medicaid initiatives (more than 80 of which are new).
The following points highlight significant aspects of the Work Plan:
1. Fraud and Abuse Prevention. The Work Plan emphasizes OIG’s commitment to preventing fraud and abuse. The OIG makes clear that it plans to continue devoting significant resources to investigating and prosecuting Medicare and Medicaid fraud and abuse.
2. Hospital Billing Issues. The Work Plan features a noticeable focus on hospital billing issues and payments for certain hospital services. This includes payments made to hospitals for beneficiary discharges that should have been coded as transfers, payments for same-day readmissions, payments for canceled surgical procedures and payments for mechanical ventilations.
3. Affordable Care Act. The Work Plan includes a review of the implementation of the Affordable Care Act’s programs and initiatives as they relate to responsibilities of HHS. The Work Plan also reviews OIG’s oversight of the funding that HHS received under the American Recovery and Reinvestment Act of 2009 relating to Medicare and Medicaid incentive payments for electronic health records and health information systems and data security programs.
4. Post-Acute Care. The Work Plan features increased scrutiny of post-acute care providers. Specifically, the Work Plan highlights OIG’s interest in examining:
5. New Areas of Focus. The Work Plan features several areas that might be surprising to those who follow the industry and current trends. The areas in which OIG has expressed an interest include:
Over the next few weeks, McGuireWoods will publish a series of articles on various focus areas and new initiatives identified in the Work Plan.