On November 10, 2016, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) released its annual Work Plan for Fiscal Year (FY) 2017. The 2017 Work Plan identifies audits and evaluations that the OIG plans to initiate as new projects beginning in FY 2017. The Work Plan also includes ongoing projects initiated prior to FY 2017, as well as revised projects that will undergo changes beginning in FY 2017. Finally, the Work Plan lists projects that have been completed since the issuance of the FY 2016 Work Plan.
Similar to previous versions, a significant overlap exists between the OIG Work Plan for FYs 2016 and 2017. However, the FY 2017 Work Plan also contains a substantial number of new initiatives, including: skilled nursing facility (SNF) reimbursement; hospice compliance with Medicare requirements; Medicare payments for service dates after individuals’ dates of death; and implementation of the Quality Payment Program (QPP). The FY 2017 Work Plan also revises several initiatives since FY 2016, including: review of long-term-care employee background checks; inpatient rehabilitation payment system requirements; and ambulance services supplier compliance with payment requirements.
The OIG protects the integrity of the Medicare and Medicaid programs through its directed reviews and audits. This brief underscores both new and revised reviews that will affect a broad range of Medicare and Medicaid providers and suppliers. Strategic Management selected reviews based on current client practice areas, high risk areas, and new initiatives. The OIG Office of Audit Services (OAS) or the OIG Office of Evaluation and Inspection (OEI) perform the reviews noted below. Health care providers and organizations may use the FY 2017 OIG Work Plan to identify corporate compliance risks, prioritize audit focus areas, and facilitate compliance program activities.
MEDICARE PART A AND PART B
Incorrect Medical Assistance Days Claimed by Hospitals (New) – Medicare allows participating hospitals that serve a disproportionate share of low-income patients to claim a disproportionate share of hospital payments. These payments are calculated based on the number of Medicaid patient days that the hospitals furnish. Hospitals provide this information in Medicare cost reports to Medicare administrative contractors (MACs). The OAS will review whether MACs properly settled the cost reports for disproportionate share payments in accordance with federal requirements.
Case Review of Inpatient Rehabilitation Hospital Patients Not Suited for Intensive Therapy (New) – Freestanding inpatient rehabilitation (rehab) hospitals, which provide intensive rehab therapy after injury, illness, or surgery, must only admit patients suited for intensive therapy. The OEI will review a sample of rehab hospitals to determine whether patients participated in and benefited from the therapy. The OEI will also identify patients that were not suited for such therapy, and note reasons for their inability to participate and benefit from therapy.