Regulatory
By Charlie Colitre, President, Healthcare Compliance Consultants
The 2010 OIG Work Plan
Each September, the Department of Health and Human Services, Office of Inspector General (OIG), publishes its work plan for the following year. The work plan outlines those areas of healthcare fraud enforcement on which the OIG will focus for the coming fiscal year.
The Centers for Medicare and Medicaid Services (CMS) Section of the 2010 Work Plan lists a large number of areas that will be scrutinized during the US Government’s Fiscal Year (FY) 2010. Within the “Other Part A and Part B Providers Payments” section, the following 22 items concerning physicians are listed:
1. Physician Billing for Medicare Hospice Beneficiaries
2. Trends in Medicare Hospice Utilization
3. Medicare Incentive Payments for E-Prescribing
4. Place-of-Service Errors
5. Ambulatory Surgical Center Payment System
6. Evaluation and Management Services during Global Surgery Periods
7. Medicare Payments for Part B Imaging Services
8. Services performed by Clinical Social Workers
9. Outpatient Physical Therapy Services Provided by Independent Therapists
10. Appropriateness of Medicare Payments for Polysomnography
11. Laboratory Test Unbundling by Clinical Laboratories
12. Medicare Billings with Modifier GY
13. Geographic Areas with a High Density of Independent Diagnostic Testing Facilities
14. Enrollment Standards for Independent Diagnostic Testing Facilities
15. Physician Reassignment of Benefits
16. Medicare Providers’ Compliance with Assignment Rules
17. Payments for Services Ordered or Referred by Excluded Providers
18. Ambulance Services used to Transport End-Stage Renal Disease Beneficiaries
19. Medicare Payments for Transformational Epidural Injections
20. Comprehensive Error Rate Testing Program: FY 2008 Transportation Claims
21. Comprehensive Error Rate Testing Program: FY 2008 Part A and Part B Error Rates
22. Medicare Services Billed with Dates of Service After Beneficiaries’ Date of Death
The annual OIG Work Plan provides physician practices an excellent opportunity to reaccess their compliance program risk areas using the applicable Work Plan items. In addition to the “Other Part A and Part B Providers Payments” items listed above, physician practices should review other sections such as “Hospitals,”Nursing Homes” and the Medicaid sections for applicable items.
The 2010 OIG Work Plan can be accessed at:
http://oig.hhs.gov/publications/docs/workplan/2010/Work_Plan_FY_2010.pdf. While you’re there check out the new OIG web site, http://oig.hhs.gov for additional compliance resources.
Healthcare Compliance Consultants is available to assist physician practices in reviewing and evaluating compliance Programs and accessing risk areas.
Mr. Colitre is President of Healthcare Compliance Consultants in Akron, Ohio. He can be reached at PO Box 19164, Akron, OH, 44319 330.753.6131 complianceconsultants.biz
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