Corporate Compliance

OIG: Hospital should refund $15,759

Compliance Monitor, March 1, 2006

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The OIG is recommending that the University of Louisville Hospital repay $15,759 after the hospital counted a graduate of a foreign dental school in it's employee count.

The OIG said that the hospital should make the repayment by filing an amended cost report.

The OIG's objective was to determine whether University of Louisville Hospital included the appropriate number of dental residents in its full-time equivalent (FTE) counts when computing Medicare graduate medical education (GME) payments for fiscal years (FYs) 2000 through 2002.

Although the hospital appropriately included dental residents in its FTE counts used to compute FYs 2000 and 2001 GME payments, in FY 2002 the hospital inappropriately included a the dental resident who was a graduate of a foreign dental school. As a result, the hospital overstated its direct and indirect GME claims by $15,759 for FY 2002. The hospital also included didactic, (e.g., classroom, time) for the residents while the residents were working in nonhospital settings.

To perform the audit, the OIG

  • reviewed applicable federal criteria, including section 1886 of the Social Security Act (the Act) and 42 CFR parts 412 and 413

  • gained an understanding of the hospital's procedures for identifying, counting, and reporting dental resident FTEs on the Medicare cost reports

  • reconciled the dental resident FTEs reported on the hospital's FYs 2000 through 2002 Medicare cost reports to supporting documentation

  • reviewed supporting documentation to determine whether the hospital appropriately included dental residents in the FTE resident counts when computing direct and indirect GME payments on the Medicare cost reports

  • reviewed financial records at the hospital and the dental school to determine whether the hospital incurred all of the costs of training dental residents in nonhospital settings and

  • summarized the audit results and provided them to the fiscal intermediary to recompute GME payments on the FYs 2000 through 2002 cost reports

      Click here to read the audit report, "Graduate Medical Education for Dental Residents Claimed by the University of Louisville Hospital for Fiscal Years 2000 Through 2002," (A-04-04-06005) issued February 8, 2006.



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