Office of Inspector General Publishes the 2007 OIG Work Plan

(PYA Alert dated January 16, 2007)

If you haven’t yet tuned into the 2007 OIG Work Plan, start bending your organization’s ear to ensure awareness. Out with the old and in with the new? Not quite. The 2007 offers a healthy mix of the old and (a lot that’s) new. As evidence, 10 out of 25 items listed in the Work Plan are new this year. Some of the familiar prior Work Plan for Medicare hospitals that remained in 2007 included:

• Upcoding of DRG payments to identify providers who exhibit high or unusual patterns for selected DRGs;
• Payments for observation services versus inpatient admission for dialysis services;
• “Inpatient-only” services performed in the outpatient setting;
• Unbundling of hospital outpatient services; and
• Outpatient department payments.

New areas of focus for hospitals include medical appropriateness and coding of DRG services, and appropriate payments for diagnostic x-rays in hospital emergency departments (which pose risk for “double dipping” for radiology services). For Medicare physicians, the Work Plan includes traditional areas of focus such as pathology, cardiography, echocardiography and wound care services. Ten new physician areas include evaluation of “incident to” services and place of service errors which are important to HIM and compliance directors in light of new Medicare Administrative Contractor (MAC) reform. MACs are new entities slated to perform all core claims processing operations for both Medicare Part A and B (e.g. hospital and physician) services.

The Work Plan will also now largely extend its traditional Medicare review focus to the Medicaid program, in keeping with the Deficit Reduction Act (DRA) of 2005 and increased emphasis (including increased federal funding) for Medicaid fraud enforcement. Out of the entire Work Plan, state false claims acts stand to impact the largest number of providers, as the OIG will review and compare the solidity of these laws to the federal False Claims Act. Other areas of new focus will include inpatient capital payments, inaccurate reporting of wage data, admission from acute-care hospitals to long-term care hospitals, and compliance with the average length of stay criteria for long-term care hospitals.

The 2007 OIG Work Plan focuses on a broad spectrum but emphasizes proper medical decision-making. Does your facility’s work plan incorporate both longtime and newer OIG initiatives to ensure compliance with the Plan? The PYA Clinical Compliance and Reimbursement team of professionals can assist you in evaluating your work plan, targeting process improvement opportunities, and educating staff to keep your organization in compliance with the 2007 Plan.

Please contact Carol Eyer at (800) 270-9629 for additional details.

The information provided via PYA Alert, Tax Planning Alert, or Audit and Accounting Alert should not be construed as accounting, auditing, consulting, or legal advice on any specific facts or circumstances. The contents are intended for general information purposes only.  Please contact us at (800) 270-9629 to discuss your specific situation or to discuss any specific questions you may have.

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