Medicare Compliance & Reimbursement

Prescription drugs are a hot topic under Medicare Part B, too.

Just because the HHS Office of Inspector General (OIG) has a slew of new initiatives in its Fiscal Year (FY) 2016 Work Plan doesn’t mean that the watchdog is slowing down or stopping its ongoing investigations. And for some providers, the recurring reviews will pose greater threats than the new ones.

According to a Nov. 11 analysis by associate attorneys Benjamin Fee and Nicole Burgmeier of Dorsey & Whitney LLP, the OIG’s 2016 Work Plan includes the following ongoing audit activities:

• Hospitals: The OIG will review the number of provider-based facilities that hospitals own and the extent to which the Centers for Medicare & Medicaid Services (CMS) has methods to oversee provider-based billing. Also, the OIG will review the challenges relating to the provider-based attestation review process. This is a revised audit activity.
• Hospice: In a revised initiative, the OIG will review the use of general inpatient care level for the Medicare hospice benefit, focusing on reviewing election statements for hospice beneficiaries who received general inpatient care and the medical necessity of services.
• Prescription drugs: The OIG will review the oversight actions that CMS and its claims processing contractors take to ensure Part B drug payments meet coverage criteria and identify challenges contractors face when making drug-coverage decisions.

More: And according to a Nov. 13 legal update by attorneys William Jackson, Diane Welsh, Meghan O’Connor, and Patrick Cannon of von Briesen & Roper S.C., in FY 2016 the OIG will continue to study:

• Indirect Medical Education (IME) payments;
• Hospital controls over wage data used to calculate Medicare wage indices;
• Adverse events occurring in long-term care hospitals (LTCHs);
• Competitive bidding, payments, and compliance for specific medical equipment and supplies, including power mobility devices, nebulizers, and diabetes testing supplies;
• The Ambulatory Surgery Center (ASC) payment system;
• Selected independent clinical laboratory billing requirements;
• Inappropriate billing for ambulance, chiropractic, and ophthalmology services;
• Qualifications of technologists who perform portable x-ray services; and
• High-use sleep-testing procedures in sleep disorder clinics.