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Recent Compliance Updates & Tips

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The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently posted a revised Work Plan for fiscal year 2015.  For each review, the revised Work Plan sets forth the subject, primary objective, criteria for evaluation, review identification code, and expected year of completion for reports.  The OIG added 20 new items in the revised Work Plan, and also removed those reviews that have been deleted, completed, postponed or canceled since October 2014.  The following list recaps some of the new initiatives found in the revised Work Plan relating to Medicare and Medicaid:

  • Review of Medicare outpatient payments for intensity-modulated radiation.
  • Review of hospital preparedness and response to high-risk infectious.
  • Examine effect of competitive bidding on Medicare beneficiaries’ access to certain types of durable medical equipment, prosthetics, orthotics, and supplies.
  • Analyze Medicare payments for clinical diagnostic laboratory tests, including the top 25 clinical diagnostic laboratory tests charged to Medicare.
  • Review provider compliance with various aspects of the Inpatient Rehabilitation Facility. Prospective Payment System, including documentation requirements for claims paid by Medicare.
  • Review extent of use of electronic health records to achieve care coordination goals by participants of the Accountable Care Organization Medicare Shared Savings Program.
  • Summarize OIG work on Medicare Part D and provide progress report on recommendations to improve CMS, plan sponsors and Medicare Drug Integrity Contractor oversight of Part D.
  • Describe Part D billing trends, including changes in billing for commonly used opioid drugs.
  • Review accuracy of state identification and reporting of increases in federal share of Medicaid rebate.
  • Analyze generic drug prices to determine whether prices increased more than the increase in inflation as measured by the consumer price index for urban consumers.
  • Review drug manufacturers’ treatment of sales of authorized generics in their calculation of average manufacturer price for the Medicaid drug rebate program.
  • Determine whether States submit complete Transformed Medicaid Statistical Information System data.

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The OIG also commented on areas they anticipate beginning work in the upcoming fiscal year and beyond.  The OIG determined these broader areas of focus based on the results of OIG past work identifying significant management and performance challenges facing HHS.  As expected, the OIG will continue reviews of the appropriateness of Medicare and Medicaid payments and examine the efficiency and effectiveness of payment policies and practices in inpatient and outpatient settings, for prescription drugs, and in managed care.  Lastly, the OIG makes clear that the Work Plan is continuously updated and changes according to needs and circumstances.  As such, the OIG does not provide status reports on the progress of the reviews and instead periodically updates their Work Plan.

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