Health Law Daily Focus remains on Medicare, Medicaid payments in 2017 OIG Work Plan
Thursday, November 10, 2016

Focus remains on Medicare, Medicaid payments in 2017 OIG Work Plan

By Patricia K. Ruiz, J.D.

The HHS Office of Inspector General (OIG) continues to put Medicare and Medicaid payments high on its list of priorities in its 2017 Work Plan. The Work Plan summarizes new and ongoing reviews and activities that the OIG plans to pursue with respect to HHS programs and operations during the current fiscal year (OIG Work Plan, November 10, 2016).

In evaluating potential projects to undertake, the OIG considers factors such as mandatory requirements for OIG reviews as set forth in laws, regulations, or other directives; requests made or concerns raised by Congress, HHS management, or the Office of Management and Budget (OMB); top management and performance challenges facing HHS; work performed by other oversight organizations; management’s actions to implement OIG recommendations from previous reviews; and potential for positive impact.

Medicare Parts A and B. The OIG has completed 15 of the activities related to Medicare Parts A and B that it listed during its previous work plan, including a nationwide analysis of common characteristics in OIG home health fraud cases and improper Medicare payment for unlawfully present beneficiaries. For 2017, the OIG is adding 24 new activities and will be reviewing inpatient psychiatric facility outlier payments, skilled nursing facility reimbursement, financial interests reported under the open payments program, and drug waste of single-use vial drugs, among other activities.

Medicare Parts C and D. The OIG completed two activities related to Medicare Parts C and D listed for the previous work plan—one related to high Part D spending on opioids and another on coverage of drugs commonly used by dual eligibles. It added five new activities for the 2017 work plan, including reviews of Part C and Part D payments for service dates after the date of the beneficiary’s death and Part D rebates related to drugs dispensed by 340B Pharmacies.

Medicaid. With respect to Medicaid, the OIG completed six activities listed in its 2016 Work Plan, including reviews of state reporting of Medicaid collections, vulnerabilities related to provider enrollment and ownership disclosure, and implementation of Medicaid enhanced provider enrollment screenings. The OIG added nine activities to its 2017 work plan, including reviews of states’ managed care organization Medicaid drug claims, fraud in Medicaid personal care services, and the treatment of health care-acquired conditions in managed care organizations.

Health insurance exchanges. The OIG completed two activities related to health insurance exchanges that it listed in its previous work plan, including reviews of the consumer operated and oriented plan loan program and state-based marketplace information system security controls. It did not add any new activities for the 2017 work plan.

Electronic health records. The OIG completed two activities it listed in its previous work plan related to electronic health records—one review of Medicaid incentive payments for adopting electronic health records and another related to hospital electronic health record contingency plans.

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