By Kelly A. Briganti, Editorial Director, G2 Intelligence
The HHS Office of Inspector General (OIG) has issued its opinion on the top things the government isn’t doing that could generate cost savings and improve quality of HHS programs and thus should be an implementation priority. The OIG’s March 2015 edition of its Compendium of Unimplemented Recommendations responds to the Consolidated Appropriations Act of 2014 mandate for the OIG to identify top 25 unimplemented recommendations that it thinks would best protect HHS programs. The Compendium includes the following among its Top 25 items needing priority attention:
- Update the “Audit Tracking and Reporting System” to make sure it “accurately reflect[s] the status of audit report recommendations” and thus ensure collection of Medicare overpayments (recommended in May 2012)
- “Reduce hospital outpatient department payment rates for ambulatory surgical center-approved procedures” (recommended in April 2014; predicted to save $15 billion)
- Implement standardized and electronic case files for appeals to improve the Medicare appeals process at the ALJ level and address a backlog that grew from 44,000 cases to 384,000 cases between 2010 and 2013 (recommended in November 2012) (for more information about Appeals issues, see the March issue of G2 Compliance Advisor)
- Develop a “comprehensive plan to address fraud vulnerabilities in electronic health records” (recommended December 2013)
The compendium’s Appendix lists not only the Top 25 issues but all “significant” unimplemented recommendations and includes two relevant to laboratories:
- Imposition of beneficiary deductibles and coinsurance to control utilization and ensure the Medicare fee schedule is in line with what physicians pay for laboratory tests. These efforts are estimated to generate $23.8 billion in savings over ten years, based on a 2008 Congressional Budget Office report.
- Review laboratories for questionable billing practices, evaluating whether “program integrity strategies … effectively identify[] program vulnerabilities associated with lab services.”
These Appendix items are not terribly new for laboratories but it reiterates that laboratories remain a top enforcement priority and target for cost savings strategies.