Recent Compliance Updates & Tips
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Review to coincide with monthly updates to OIG Work Plan
The OIG announced that its work planning process is being modified to be more dynamic and to reflect the adjustments made throughout the year in response to changing priorities and new emerging issues. The OIG, as of June 15, 2017, will now adjust its Work Plan on a monthly basis rather than semi-annually as has been done previously, to ensure that it more closely aligns with the work planning process. The monthly updates will include the addition of newly initiated Work Plan items and removal of completed items. The Work Plan sets forth various audits and evaluations that are underway or planned during the fiscal year and beyond. In the first monthly update, the OIG added a project to follow up on CMS management of the Quality Payment Program (QPP), a new initiative intended to shift Medicare from a volume-based payment system to one that rewards value. The OIG plans to assess CMS’s progress in addressing key challenges to implementing the QPP. The OIG’s Office of Evaluation and Inspection will perform the assessment and issue the report in 2018.
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This review will be a follow up to the December 2016 reported findings, where the OIG identified CMS’s five key management priorities regarding the planning and implementation of the QPP. Early on, CMS staff decided that clinicians’ acceptance of the QPP and readiness to participate in it would be the most critical factor to ensuring the program’s success. This focus on clinicians informed CMS’s decisions regarding its other management priorities, including: adopting integrated internal business practices to accommodate a flexible, user-centric approach; developing information technology (IT) systems that support and streamline clinician participation; developing flexible and transparent MIPS policies; and facilitating participation in Advanced APMs. The OIG identified two aspects of QPP implementation that require particular focus: (1) providing sufficient guidance and technical assistance to ensure that clinicians are ready to participate in the QPP; and (2) developing backend information technology (IT) systems to support key QPP functions such as data reporting and validation. If CMS does not fully address these issues, QPP implementation may be delayed, fewer clinicians may participate, and the program may fail to achieve its goals.
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