Each month, we are pleased to share the most recent additions to the 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 June’s OIG Work Plan are the following:
- ORR and Grantee Facilities’ Steps to Ensure Health and Safety of Unaccompanied Children
- Denials and Appeals in Medicare Part D
- Inappropriate Denial of Services and Payment in Medicare Advantage
- National Background Check Program: Assessment of Concluded State Grant Programs in 2017
- Accountable Care Organizations’ Strategies Aimed at Reducing Spending and Improving Quality
June’s agenda includes 9 new items from OIG. Let’s walk through some of these updates so you can address each item within your compliance program, if applicable.
ORR and Grantee Facilities’ Steps to Ensure Health and Safety of Unaccompanied Children
Immigration and child care continue to be in the news and a critical topic for the U.S. government as well as for many American citizens evaluating how refugees, immigrants, and non-citizens are being treated. For June, OIG has announced a review of the Office of Refugee Resettlement (ORR) and more specifically, the Unaccompanied Alien Center (UAC) program when children’s health and safety come into play.
The review will focus on the safety and well-being of children in the custody of the ORR, a part of the Office of the Administration for Children and Families, given the sudden increase in care required. Some areas of focus will contain review and evaluation of proper background screening, clinical training and skills of certain employees, facility security, and response and identification for incidents of harm that may have occurred.
Read the full update from OIG here.
Denials and Appeals in Medicare Part D
The Office of Inspector General HHS will be examining the Centers for Medicare and Medicaid’s oversight of drug denials and appeals for Medicare Part D for 2014-2016. Because CMS uses a capitated payment model, incentives can be created to increase profits for private insurers.
To find out more about how OIG is evaluating CMS’ efforts when it comes to Medicare Part D, visit here.
Inappropriate Denial of Services and Payment in Medicare Advantage
Many Americans rely on primary care and medical procedures to be paid through Medicare Advantage. Sometimes, these necessary services are denied for numerous reasons and the OIG will be investigating prior medical records to review the extent to which some parties were denied authorization or payments from CMS.
The model for payment for these services can become a bit controversial when it comes to incentives for denying access and reimbursement for care in some circumstances. OIG has outlined their thoughts below when it comes to this situation.
“Capitated payment models are based on payment per person rather than payment per service provided. A central concern about the capitated payment model used in Medicare Advantage is the incentive to inappropriately deny access to, or reimbursement for, health care services in an attempt to increase profits for managed care plans.”
Read more on this review here.
National Background Check Program: Assessment of Concluded State Grant Programs in 2017
To help states implement background check programs for long-term care services, CMS is authorized to present grants in accordance with the Patient Protection and Affordable Care Act (ACA § 6201).
The CMS National Background Check Program upon completion is required by ACA to be evaluated by OIG to determine if states implemented correct procedures for background checks on employees with direct access to patients in long-term care facilities.
To read more on this assessment, follow the link here.
Accountable Care Organizations’ Strategies Aimed at Reducing Spending and Improving Quality
CMS has been highly active in eliminating extra hoops and costs for providers and health systems to jump through in order to provide better quality care to patients in a timely manner. Accountable Care Organizations (ACOs) were introduced by the Medicare Shared Savings Program (MSSP) to help in the efficiency and quality of service delivery to patients, infrastructure investments, coordination of services and items, and hospital accountability.
OIG will be evaluating the strategies of ACOs to reduce costs and improve the overall quality of care. To discover more about these improvements, read on here.
Other updates to the June 2018 OIG Work Plan include the following:
- CMS’s Contingency Planning for Information Technology Systems
- Review of Home Health Claims for Services With 5 to 10 Skilled Visits
- Medicare Part B Payments for End-Stage Renal Disease Dialysis Services
- State and Territory Response and Recovery Activities for the 2017 Hurricanes
Do you have any recent experience or information concerning OIG’s Work Plan updates for June? 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.