It’s time again

Each fall the OIG releases its Annual Work Plan for compliance so healthcare organizations can get an idea of the status of items from the year before as well as a roadmap of what areas and specific items the OIG will focus its efforts in the next year.

The OIG released its 2017 Work Plan in November this year. As to be expected, there were updates on studies and tasks that are ongoing on, as well as, new studies and areas that the OIG will concentrate on in 2017.

This blog will focus on the Legal Enforcement sections of the 2017 OIG Work Plan.

So far in 2016…

Exclusions: The OIG excluded 3,635 individuals and entities

Civil Fines and Monetary Penalties: 56 fines have been issued for a total of $7,201,781, averaging $128,603 per fine
VIEW 2016 COMPLIANCE DATA

Coordinated Healthcare Task Force Enforcements
In 2016, The HEAT Strike Forces continued its coordinated efforts of working with law enforcement, DOJ, FBI and CMS to target and prosecute fraud and abuse in healthcare. There are nine core cities that these HEAT Strike Forces have set up shop.

Specific areas that the OIG has expressed continued concern are cases involving fraud and and abuse related to:

  • Controlled and non-controlled prescription drugs
  • Home health agencies, personal care, and home and community based services.
  • Ambulance Transportation
  • Durable medical equipment
  • Diagnostic Radiology and Laboratory testing.
  • False Claims and Billings
  • Quality of Care
  • Assisting Medicaid Fraud Control Units (MFCU) in investigations
  • Payments made for services after a person is deceased, and
  • Organized crime activity in healthcare fraud

Reports and Tasks we are Following
There are several important reports on compliance that were completed in 2016 and should be reviewed for more guidance:

  • Nationwide Analysis of Common Characteristics in OIG Home Health Fraud Casss (OEI 05-16-00031, issued June 2016)
  • Medicare- Vulnerabilities Related to Provider Enrollment and Ownership Disclosure (OEI 04-11-00591, issued May 2-16)
  • Revised. National Background Checks for Long-Term Care Employees-Mandatory Review.
  • Medicaid: Vulnerabilities Related to Provider Enrollment and Ownership Disclosures (OEI-04-11-00590, issued May 2016)
  • Medicaid Enhanced Provider Enrollment Screenings Have Not Been Fully Implemented (OEI-05-13-00520, issued May 2016.

Summary
The OIG continues on its forward path of focusing on fraud and abuse in healthcare and feels a deep commitment to returning those dollars to the Medicare and Medicaid Trust Funds on behalf of the U.S. Taxpayer. This is the time to review your compliance program and in particular to ensure that you are conducting monthly monitoring of and for exclusions at the state and federal level.

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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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