Each month, we are pleased to share the most recent additions to the HHS Office of Inspector General (OIG) Work Plan items. Starting in June 2017 – OIG has been updating their Work Plan monthly with any new changes to the active list. Let’s take a look at the new points from this month.
A few topics that stood out to us for August’s OIG Work Plan are the following:
- Review of States’ Oversight of Opioids
- Potential Abuse and Neglect of Children Receiving Medicaid Benefits
- CMS Oversight of Nursing Facility Staffing Levels
- Physicians Billing for Critical Care Evaluation and Management Services
- Penetration Test of the Affordable Care Act Website and Associated Systems
August’s agenda includes 11 new items from OIG. Let’s walk through some of these updates so you can address each item within your compliance program, if applicable.
Review of States’ Oversight of Opioids
As the HHS OIG and DOJ continue to combat the opioid epidemic nationally, individual states will be evaluated to support “ongoing efforts to identify and disseminate effective practices to address the opioid epidemic in the United States”.
A review will be conducted specifically addressing each state’s policies and procedures, data analytics, programming, and outreach when it comes to opioid prescribing and monitored use.
Read the full update from OIG here.
Potential Abuse and Neglect of Children Receiving Medicaid Benefits
The Office of Inspector General will be taking a further look at claims from Medicaid beneficiaries in which potential abuse or neglect of children has taken place.
States are required to report suspected child abuse, but the variation in each state’s definition, procedures, and scope can be difficult to compare. OIG has extensive experience with identifying problems in quality of care and reporting in similar environments such as skilled nursing facilities, group home, and nursing home populations. In this regard, they will be taking these measures to evaluate the process and care for potentially neglected or abused children receiving Medicaid benefits.
Find out more information here.
CMS Oversight of Nursing Facility Staffing Levels
Finding enough nursing staff remains a challenge for facilities across the country. With an increased demand for quality nurses and the mobility of such large workforces, the level of hiring and tracking of employees can be tricky. In particular, implementing and controlling license verification and sanction screening is critical to ensuring the most qualified and quality people are joining your team.
When the quality of care and accuracy of nurse documentation come into play, OIG will be examining nursing staffing levels submitted to the Centers for Medicare and Medicaid Services (CMS) and the Payroll-Based Journal. The Office of Inspector General (HHS) will be enforcing minimum requirements for staffing, as well as incentivizing higher quality recruitment that goes beyond the bare minimum.
Click here to find out more about this update.
Physicians Billing for Critical Care Evaluation and Management Services
Critical care is defined as the direct delivery of medical care by a physician(s) for a critically ill or critically injured patient. Critical care is usually given in a critical care area such as a coronary, respiratory, or intensive care unit, or the emergency department”.
Medicare reimburses physicians according to the amount of time they are spending with each patient. The physician must be immediately available for the beneficiary in critical condition for monitoring and evaluation. The following review from OIG will be determining if payments for Medicare are appropriate for critical care patients according to Medicare requirements.
Read more about this topic here.
Penetration Test of the Affordable Care Act Website and Associated Systems
Data integrity and online security are so crucial to an interactive experience and general organizational efficiency. When the Federally Facilitated Marketplace (FMM) and Healthcare.gov were created under the Affordable Care Act, the goal was to provide access to healthcare coverage via federal programs and private qualified health plans.
In 2017, more than nine million individuals were enrolled through FFM, and OIG will be testing ACA systems for effective data security provided by the Centers for Medicare and Medicaid Services.
Read more on this subject here.
Other updates to the August 2018 OIG Work Plan include the following:
- Hospitals’ Compliance with Medicare’s Transfer Policy With the Resumption of Home Health Services and the Use of Condition Codes
- Review of Federal Programs Administered by American Indian and Alaska Native Tribes
- Blood Lead Screening Tests, Followup Services, and Treatment for Medicaid-Enrolled Children
- ACF Child Care Development Fund: Program Integrity
- Medicare Payments for Clinical Diagnostic Laboratory Tests in 2017: Year 4 of Baseline Data
- Medicare Market Shares of Mail Order Diabetic Test Strips from April-June 2018
Do you have any recent experience or information concerning OIG’s Work Plan updates for August? Maybe there’s a question you are urgent to ask for more insight.
Let us know in the comments below!
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Written by Michael Rosen, ESQ
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.