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 items from this month.
January’s agenda includes just six new items from HHS Office of Inspector General (OIG). Let’s walk through these updates so you can address each item within your compliance program, if applicable.
- States’ Compliance with New Requirements to Prevent Medicaid Payments to Terminated Providers
- Followup Review on Inpatient Claims Subject to the Post-Acute-Care Transfer Policy
- Utilization and Pricing Trends for Naloxone in Medicaid
- Duplicate Payments for Home Health Services Covered Under Medicare and Medicaid
States’ Compliance with New Requirements to Prevent Medicaid Payments to Terminated Providers
According to the 21st Century Cures Act, the Centers for Medicare and Medicaid Services (CMS) is required to give terminated provider information to each state. This action prevents Medicaid enrollees from being treated by terminated providers, and to also ensure no federal dollars are paid out for such services with excluded providers.
The study has been mandated by the Cures Act and will help identify how thorough the system for keeping track of terminated providers on a state level is being implemented in regards to the CMS terminations database. State contracts with managed care entities will also be examined to understand how many states include a terminated provider provision for managed care networks.
Read the full update from OIG here.
Followup Review on Inpatient Claims Subject to the Post-Acute-Care Transfer Policy
An update to the CMS Post-Acute-Care Transfer Policy helps define the discrepancies in payment between associated costs of beneficiary transfer to a post-acute facility (home health services, skilled nursing facilities (SNFs), non-Inpatient Prospective Payment System (IPPS) hospitals or hospital units) versus a direct-to-home discharge.
HHS OIG has found that some overpayments have occurred because of improper billing for types of services and situation provided after transfer. The HHS Office of Inspector General (OIG) recommended changes to CMS for Common Working File (CWF) edits for overpayments and recoveries. After CMS agreed to these changes, HHS OIG will be auditing the effectiveness of corrections to CWF edits.
Find out more information here.
Utilization and Pricing Trends for Naloxone in Medicaid
Increasing access to Naloxone has been a priority for the U.S. Surgeon General and the Centers for Medicare and Medicaid Services (CMS) to help curb the opioid epidemic. However, costs of Naloxone remains high as the government looks to help provide more assistance.
HHS OIG will produce a data brief to help provide more information for how to provide more eligible Medicare beneficiaries with this drug in a cost-effective way.
Check out this new Work Plan item, here.
Duplicate Payments for Home Health Services Covered Under Medicare and Medicaid
Medicare Home Health Agencies are responsible for providing all services either directly or under arrangement while a beneficiary is under a home health plan of care authorized by a physician.
In some instances, “dual eligible beneficiaries” exist when both Medicare and Medicaid apply to an individual. In these cases, duplicate payments may occur between both agencies. OIG will be discovering “whether States made Medicaid payments for home health services for dual eligible beneficiaries who are also covered under Medicare”.
To read the full update, visit the HHS OIG website here.
Other updates to the January 2019 OIG Work Plan include the following:
- Medicare Payments for Clinical Diagnostic Laboratory Tests in 2018: Year 1 of New Payment Rates
- Medicare Outpatient Outlier Payments for Claims With Credits for Replaced Medical Devices
Do you have any recent experience or information concerning OIG’s Work Plan updates for January? 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.