2015 OIG Work Plan Highlights: Nursing Home Services

We recently highlighted the home health and hospice services sections of the 2015 OIG Work Plan. Today, we’ll delve deeper into the nursing home services section:

Medicare Part A billing by skilled nursing facilities. The OIG will describe skilled nursing facility (SNF) billing practices and the differences among SNFs in specific years. The OIG found that SNFs billed one-quarter of all 2009 claims in error, resulting in $1.5 billion in inappropriate Medicare payments. The OIG notes that CMS has made significant changes to how SNFs bill for Medicare Part A stays.

Questionable billing patterns for Part B services during nursing home stays. The OIG will identify and review questionable billing patterns of nursing homes and Medicare providers for Part B services provided to nursing home residents during stays not paid under Part A.

State agency verification of deficiency corrections.The OIG will determine whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys. Federal regulations require nursing homes to submit correction plans to the State survey agency or CMS for deficiencies identified during surveys.

Program for national background checks for long-term-care employees. The OIG will review the procedures implemented by participating States for long-term-care facilities or providers to conduct background checks on prospective employees and providers who would have direct access to patients.

Hospitalizations of nursing home residents for manageable and preventable conditions. The OIG will determine the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting. The OIG states hopitalizations of nursing home residents may indicate quality-of-care problems in nursing homes.

Click here to see the plan.

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2015 OIG Work Plan Highlights: Hospice Services

Yesterday, we highlighted the home health services section of the 2015 OIG Work Plan. Today, we’ll take a closer look at the hospice services section of the Work Plan:

For beneficiaries living in assisted living facilities, the OIG will review the level of services provided, including the length of stay, level of care received and common terminal illnesses. This information is necessary for CMS to reform the hospice payment system, collect data relevant to revising hospice payments, and develop quality measures. Furthermore, hospice care may be provided to individuals and their families in various settings. These settings include the beneficiary’s place of resident, such as an assisted living facility. Typically, assisted living facility residents have the longest lengths of stay in hospice care, thus requiring more monitoring and examination.

The OIG will also assess the appropriateness of hospices’ general inpatient care claims and the content of election statements for hospice beneficiaries who receive general inpatient care. The OIG will review hospice medical records to address concerns that this level of hospice care is being misused. Beneficiaries may revoke their election of hospice care and return to standard Medicare coverage at any time.

Click here to see the plan.

OIG 2015 Work Plan Released

The Office of the Inspector General (OIG) has just released its 2015 Work Plan and it looks a lot like its 2014 plan. The OIG will still be focused on inappropriate Part A and Part B billing in Nursing Facilities; general inpatient care billing for Hospice; compliance with PPS requirements in home health, with special scrutiny on newly enrolled home health agencies as well as review of employment of individuals with criminal convictions in the home care setting. The OIG will also still be looking at inappropriate Part B billing for Chiropractor services; place of service coding errors for Physician services; and the high use of outpatient Physical Therapy services.

To read the OIG’s full plan, click here.

Stark Law & Anti-Kickback Waivers Extended For ACOs

The Office of the Inspector General and CMS recently announced that waivers to the Anti-Kickback Statute and Stark Law for Medicare Shared Savings Program accountable care organizations will be extended through November 2, 2015. CMS and the OIG published an interim final rule with a comment period that established waivers of the applications of Stark Law, the Anti-Kickback Statute and certain civil monetary penalties to ACOs participating in the Shared Savings Program on November 2, 2011. According to the interim final rule, the waivers were to expire next month. Extending the waivers will support agencies’ goals “to balance effectively the need for ACO certainty, innovation, and flexibility in the Shared Savings Program with protections for beneficiaries and the Medicare program.”

Click here to see the interim final rule.

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Medicare Inappropriately Paid LTCHs Millions Of Dollars

According to a new report from the Department of Health and Human Services’ Office of Inspector General (OIG), Medicare made millions in inappropriate payments to long-term care hospitals (LTCHs) due to problems in the program’s pay system for LTCH readmissions. The program paid LTCH $4.3 million for interrupted stays in 2010 and 2011 and $12 million to 59 LTCHs with high numbers of readmissions following the fixed day period (the number of days after which Medicare pays LTCHs for a second stay for a returning beneficiary). The program also paid $3.1 million to 24 LTCHs with high readmissions following several short stays at intervening facilities.

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OIG Report: Documentation Coding Errors Costing Medicare Billions

According to a new OIG report, documentation coding errors related to routine patient evaluation and management (E/M) visits are costing Medicare billions of dollars in improper payments a year. The investigation found that nearly $7 billion dollars in improper payments were made in 2010 alone. Most of the losses were the due to bills that were incorrectly coded and/or lacking documentation; 42% of claims for E/M services in 2010 were incorrectly coded and 19% lacked proper documentation. However, only about 4% of the visits analyzed were for initial or subsequent skilled nursing care-most of the claims were for “established patient office/outpatient visits.”

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OIG Official: Feds To Cut Back Medicare Oversight in FY 2014

The Department of Health and Human Services Office of the Inspector General anticipate reducing Medicare and Medicaid oversight activities by 20% in fiscal year 2014. If HHS does indeed scale back its investigations, it could mean a reprieve for LTC providers that have faced increasing scrutiny from OIG and other watchdogs. OIG officials say that budget cuts are to blame. During a hearing on efforts to reduce Medicare waste, fraud and abuse, OIG officials urged the subcommittee to support OIG’s 2015 budget request: the proposed White House budget calls for a 6 percentage point increase, bringing the OIG budget to $75 million. However, the House subcommittee did not “share the provider perception that fraud and abuse oversight has become too onerous.” Members say more has to be done and “lambasted CMS and OIG for being ineffectual.”

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