HHS Office of Inspector General Issues 2015 Work Plan (Part 2)

This final post on the OIG’s 2015 Work Plan summarizes many of the OIG’s initiatives in other areas.  To read Part 1, click here.

Medical Equipment and Sales: The OIG plans to examine 10 areas regarding equipment and supplies, including issues relating to power mobility devices, lower limb prosthetics, nebulizer machines and related drugs, diabetes testing supplies, and the payment system for renal dialysis services and drugs.  The OIG will also review claims for frequently replaced medical equipment supplies to determine supplier compliance with medical necessity, frequency, and other Medicare requirements, noting that suppliers have automatically shipped certain device supplies without physician orders for refills.

Other Providers: The OIG plans to review other providers’ policies, practices, and billings and payments, including ambulance, anesthesia, chiropractic, diagnostic radiology, imaging, and clinical laboratory services. The OIG also will examine inappropriate and questionable billing by ophthalmologists, physician place of service coding errors, high use of outpatient physical therapy services, supplier compliance with transportation and set-up fee requirements for portable X-ray equipment, and high use of sleep-testing procedures by sleep disorder clinics.

Prescription Drugs: The OIG will review several areas relating to prescription drugs. Of note, the OIG plans to examine payments for drugs purchased under the 340B Drug Pricing Program by determining how much Medicare Part B spending could be reduced if Medicare could share the savings for drugs purchased under the 340B program.

Part A and B Contractors: The OIG plans to examine seven areas relating to oversight of contracts and contractor functions and performance.

Information Technology Security, Protected Health Information, and Data Accuracy: Of note, the OIG plans to examine whether CMS oversight of hospitals’ security controls over networked medical services is adequate to protect electronic-protected health information. The OIG states that computerized medical devices that are integrated with electronic medical records and a health network are a growing threat to the security and privacy of health information. These medical devices monitor a patient’s health status and transmit and receive health data.

Other Part A and Part B Program Management Issues: The OIG will examine enhanced enrollment screening procedures for Medicare providers under the ACA. For the first time, the OIG will conduct a risk assessment of the Pioneer Accountable Care Organization Model.

Medicare Part C and Part D: The OIG plans several activities regarding Medicare Part C and Part D, including Medicare Advantage Organizations’ compliance with Part C requirements, ensuring dual -eligible patient access to drugs under Part D, and Part D billing and payments including Medicare Part D payments for HIV drugs for deceased beneficiaries.

Medicaid Program: The OIG will investigate several areas relating to Medicaid, noting that protecting Medicaid from fraud, waste, and abuse takes on a heightened urgency as the program continues to expand. Thus, the OIG will investigate a variety of areas in the Medicaid program, including state claims for drug rebates and claims for federal reimbursement. The OIG will also review Medicaid payments by states for home health services and other community-based care, including determining whether adult day care services providers complied with federal and state requirements and whether home health agency health care workers were screened in accordance with federal and state requirements. In addition, the OIG will review issues relating to medical equipment and supplies, transportation, health care-acquired conditions, and managed care. Finally, the OIG will review a variety of issues regarding state management, funding, oversight, and payment for Medicaid.

Other: The OIG plans to review and investigate many other areas. For the first time, the OIG will determine the extent to which hospitals comply with the contingency planning requirements found in the Health Insurance Portability and Accountability Act (HIPAA), as well as compare the hospitals’ contingency plans with government and industry recommended practices.