Needless to say, 2017 has been an action-packed year, and even more so in the healthcare setting. We’ve seen many changes in the form of institutions, regulations, leadership, and innovation. Let’s take a walk down memory lane to discuss some of the big changes this year, and investigate what the future may hold for healthcare compliance professionals.

Office of Inspector General (OIG) 2017 Four Priority Areas

This year we saw a few key points of emphasis from OIG at HHS including the following:

  • Fighting opioid and prescription drug abuse
  • Protecting the health and safety of children served by HHS programs  
  • Preventing improper payments and fraud in home-based services
  • Partnering with states to enhance Medicaid program integrity

2017 OIG Resources 

Effective June 15, 2017, OIG began releasing Work Plan updates monthly. We are not sure if this means there will not be an annual Work Plan, as there has been each year in the past, or if it will be a compilation of monthly updates for 2018.  The OIG has traditionally released its annual Work Plan between October and November of each year- as of December 2017, the OIG has not released an Annual 2018 Work Plan.

The Fall Semiannual Report to Congress was released this year and covered OIG activities from April 2017 through September 2017. To take a closer look regarding this release, check out our blog Lessons Learned from OIG Semiannual Report to Congress.

In the OIG Top Management and Performance Challenges Facing HHS report, OIG identified the top 10 challenges facing the Department of Health and Human Services. This list also includes the top priorities for OIG as outlined above. By identifying particular constraints and pressing issues, OIG aids in helping HHS fulfill its mission “to enhance the health and well-being of Americans by providing effective health and human services and by fostering sound, sustained advances in the sciences underlying medicine, public health, and social services.”

A high priority this year for OIG and one that continues to garner immediate attention is addressing the opioid epidemic. In an effort to raise awareness and combat this terrible issue, OIG has released many materials and media. Check out one of their latest podcasts with Guest Michael Cohen to hear how federal agencies and law enforcement are pushing back.

OIG Measuring Compliance Program Effectiveness
OIG Compliance 101

OIG is focused on presenting the best materials for providers to easily understand best practices and what to expect from an enforcement standpoint. This year, a resource page was created called OIG Compliance 101, equipped with helpful educational information to help set each compliance officer on a course for success. 

In the Measuring Compliance Program Effectiveness: A Resource Guide, a roundtable was created with compliance professionals to discuss ways to measure the effectiveness of compliance programs across the country. Donna Thiel – Chief Compliance Officer here at ProviderTrust, was asked to join and contribute to the discussion.

This was a historic year for OIG as they, along with state and federal law enforcement partners, participated in the largest healthcare fraud takedown in history last July. Take a look at some of the statistics from this large operation. 

OIG 2017 Takedown statistics

Compliance Healthcare Index Report

Did you know these states make up the top 5 with the largest volume of excluded individuals/entities?

  1. California
  2. New Jersey
  3. New York
  4. Pennsylvania
  5. Texas

Tracking down exclusions is a thorough and difficult process. With so many state lists to check in addition to the LEIE  and SAM as well as delays and accuracy in MFCU reporting to OIG, it is easy to be overwhelmed. According to our data, the average time it takes for states to report exclusion issues to OIG is 169 days.

2017 Medicare FFS Improper Payment Rate Drops

The Centers for Medicaid and Medicare announced this November that 2017 Medicare Fee-For-Service improper payment rate is below 10 percent for the first time since 2013. From a provider’s perspective, this announcement demonstrates the value of leading an effective compliance department with an annual decrease of Medicare FFS improper payment of 1.5%. To read more on this story, visit the CMS blog and read the statement from Principal Deputy Administrator for Operations – Kimberly Brandt.

Summary:

Yes, this year was quite a roller coaster – far too many highlights to mention in a blog post. What are some of the significant items or news that you took away from 2017? We’d love to hear how you are tackling these constraints and opportunities, and preparing your team for next year. Get the conversation going by leaving a comment below!

We recorded a special webinar to help address the challenges of 2017 and discuss where healthcare compliance could go in 2018. In this quick session, you’ll hear about provider news, CMS enforcement and updates, exclusion data by state, and points of emphasis from OIG.


Written by Michael Rosen, ESQ

ProviderTrust Co-Founder, mrosen@providertrust.com

Michael brings over 20 years of experience founding and leading risk mitigation businesses, receiving numerous accolades such as Inc Magazine’s Inc 500 Award and Nashville Chamber of Commerce Small Business of the Year.

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