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 updates from this month.  

What is the OIG Work Plan?

The HHS OIG Work Plan sets forth various projects that OIG plans to undertake during the fiscal year (FY) and beyond.

Projects listed in the Work Plan span HHS’s operating divisions, including the following: 

  • Centers for Medicare & Medicaid Services (CMS)
  • Public health agencies such as the Centers for Disease Control and Prevention (CDC)
  • National Institutes of Health (NIH)
  • Administration for Children and Families (ACF)
  • Administration for Community Living (ACL)
  • Various state and local governments – evaluating the use of federal funds as well as the administration of HHS

*Some of the projects described in the Work Plan are statutorily required.

The October agenda includes 6 new items from HHS Office of Inspector General (OIG). Let’s walk through this latest release so you can address it within your compliance program, if applicable. 

  1. Review of Hospice Inpatient and Aggregate Cap Calculations

  2. Review of Medicare Part B Urine Drug Testing Services

  3. Supplier Compliance with Medicare Requirements for Replacement of Positive Airway Pressure Device Supplies

  4. An Assessment of the U.S. Food and Drug Administration’s Postmarket Surveillance of Medical Devices


Review of Hospice Inpatient and Aggregate Cap Calculations

To ensure that hospice care does not exceed the cost of conventional medical care at the end of life, Medicare imposes two annual limits to payments made to hospice providers: the inpatient cap and the aggregate cap. Any amount paid to a hospice for its claims in excess of the aggregate cap is considered an overpayment and must be repaid to Medicare.

Medicare administrative contractors (MACs) are in charge of overseeing the cap process. Hospice facilities must file their self-determined aggregate cap determination notice with their MAC no later than 5 months after the end of the cap year and remit any overpayment due at that time. HHS OIG will be evaluating hospice cap calculations to determine payment amounts in excess of the inpatient cap.


Supplier Compliance with Medicare Requirements for Replacement of Positive Airway Pressure Device Supplies

Finding healthcare suppliers, vendors, and affiliates who meet Medicare requirements can be challenging at times. Because CMS primarily operates under a “pay-and-chase” model,  many risks of fraud, waste, and abuse (FWA) exist in the current healthcare environment and leave beneficiaries vulnerable and taxpayers on the hook for criminal activity. It’s essential for healthcare systems and organizations to implement and promote a healthy supply chain and vendor onboarding strategy to remain compliant with federal healthcare programs.

One such example of supplier compliance involves Medicare claim reimbursement for PAP devices. HHS OIG will be reviewing claims for frequently replaced PAP device supplies at selected suppliers to determine whether documentation requirements for medical necessity, frequency of replacement and other Medicare requirements were met.


An Assessment of the U.S. Food and Drug Administration’s Postmarket Surveillance of Medical Devices

The U.S. Food and Drug Administration (FDA) frequently receives and gathers medical device safety and effectiveness information from a postmarket setting. Because of this, HHS OIG will be conducting an assessment of FDA medical device surveillance to ensure the system can identify and act on safety signals. HHS OIG will also be describing how the FDA plans to integrate med device surveillance into the National Evaluation System for health Technology (NEST).

Find the full list of Recently Added Items on OIG’s site. Take a look at our recaps of all the archived releases by visiting the ProviderTrust Work Plan page.


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ProviderTrust Mike Rosen Cofounder

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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