COMPLIANCE PLANS

OIG Work Plan Monthly Review: July 2018

None of the six new items that OIG added to its Work Plan last month directly impact labs.

1. Identification of HHS Cybersecurity Vulnerabilities

Questions: Where are the cybersecurity vulnerabilities in the HHS’s Secretary Office and Operating Divisions’ IT systems?

OIG Action: The OIG will perform a series of IT audits to find out.

2. Review of Post-Operative Services Provided in the Global Surgery Period

Issue: Section 523 of MACRA requires CMS to collect data on post-operative services included in global surgeries and requires OIG to audit and verify a sample of the data collected.

OIG Action: The OIG will review a sample of global surgeries to determine the number of post-operative services documented in the medical records and compare it to the number of post-operative services reported in the CMS data to verify the accuracy of the number of post-operative visits reported to CMS by physicians and determine whether global surgery fees reflected the actual number of post-operative services that physicians provided to beneficiaries during the global surgery period.

3. Review of Outpatient 3-Dimensional Conformal Radiation Therapy (3D-CRT) Planning Services

Issue: Hospitals use CPT code 77295 to bill Medicare for developing a 3D-CRT treatment plan. Automated prepayment edits prevent additional payments for separately billed radiation planning services billed on the same date of service as the 3D-CRT treatment plan. Additional payments are allowed if they’re billed on a different date of service. For a form of radiation similar to 3D-CRT, Medicare bans payments for separately billed radiation planning services billed on a different date of service.

OIG Action: The OIG will determine how much Medicare could have saved had it implemented the same requirements for 3D-CRT planning services.

4. Increased Payments for Transfer Claims with Outliers

Issue: Under the transfer rule, CMS reduces the DRG payment by applying a graduated per diem payment on the Medicare claim of the hospital transferring the patient to another setting early in the hospital stay. Since DSH and IME payments are a percentage of the reduced DRG payment, they’re also reduced. By contrast, by reducing the threshold above which a claim qualifies as an outlier, the outlier methodology may cause an increase in the outlier payment in transfer cases.

OIG Action: The OIG will do a report describing the extent to which additional Medicare outlier payments negate the reduction in DRG, DSH and IME payments of transfer claims.

5. HRSA Oversight of Funds for Access Increases in Mental Health and Substance Abuse Services (AIMS)

Issue: In 2017, HRSA awarded $200.5 million in AIMS grants to 1,178 health centers nation-wide to expand access for existing Health Center Program grant recipients to mental health and substance abuse services, focusing on treatment, prevention and awareness of opioid abuse.

OIG Action: The OIG will review HRSA’s internal controls to determine if they’re suitable for: (1) awarding AIMS grants; and (2) monitoring AIMS grant recipients.

6. SAMHSA’s Oversight of Accreditation Bodies for Opioid Treatment Programs

Issue: SAMHSA issued final regulations establishing an oversight system for treatment of substance use disorders with Medication-Assisted Treatment, including procedures for an entity to become an approved accreditation body for evaluating opioid treatment programs (OTPs).

OIG Action: The OIG will perform a series of audits on SAMHSA-approved accrediting bodies with accredited OTPs to determine if SAMHSA’s oversight of accreditation bodies met federal requirements.

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