Corporate Compliance

Note from Hugh

Medicare Insider, October 16, 2007

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This week, CMS seems to be taking a break so I thought I would go back and note some significant additions to the Office of Inspector General (OIG) Work Plan, included in last week's edition of Hugh Aaron's Medicare Weekly Update. You can read the OIG Work Plan here.

The OIG seems to be switching its focus from particular coding and modifier issues to cost report based payments and the factors that drive the Inpatient Prospective Payment System (IPPS) payment rates. The OIG added audits of the capital portion of the IPPS payment, disproportionate share payments, and new technology add-on payments. It is also continuing to evaluate the accuracy of wage data under the current process.

In addition the OIG has added, or is conducting on-going audits, in nearly every area that continues to be paid on a cost basis. These include:

  • Graduate medical education
  • Nursing and allied health education
  • Organ procurement
  • Bad debt reimbursement

One new addition to the Work Plan involves x-rays in the ER. The OIG cites the Medicare Payment Advisory Commission's concerns regarding their overuse. Other interesting items added to the Work Plan include an evaluation of the Medicare Secondary Payer procedures and an evaluation of The Joint Commission accreditation process.

I'm sure we will see CMS back in action next week as they gear up to publish the Outpatient Prospective Payment System final rule in November.

~ Kimberly Anderwood Hoy, Esq.

Editor's Note: Kimberly Anderwood Hoy, director of Medicare and compliance for HCPro, is the author of this week's "Note from Hugh" in Mr. Aaron's absence.

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