By Brian T. Gannon and David A. Valent

The U.S. Department of Health and Human Services (HHS), Office of Inspector General (OIG), recently released its “Work Plan” for fiscal year 2015.  The Work Plan summarizes new and ongoing endeavors that the OIG plans to pursue with respect to HHS programs and operations during this fiscal year.  The OIG’s announcement identified 135 areas of focus, including many initiatives targeted at increased oversight of Medicare and Medicaid providers.

Indeed, the OIG takes responsibility for protecting the integrity of the HHS programs, including Medicare and Medicaid, by detecting and preventing fraud, waste and abuse, by identifying opportunities to improve the program, and by holding accountable those who do not meet program requirements.  In fiscal year 2014 with programs directed by the OIG, including audits and investigations, the government recovered $4.9 billion dollars. 

In 2015, areas of focus identified in the “Work Plan” include: hospital billing, hospital quality and safety issues, and hospital privileging issues. With regard to nursing homes, the focus will be: Medicare Part A billing by skilled nursing facilities, questionable billing patterns for Part B services during nursing home stays, improved background checks for long term care employees, and hospitalization of nursing home residents for manageable and preventable conditions.  With regard to other providers and suppliers, there will be a focus on: ambulatory surgical centers, end stage renal disease facilities, ambulance services, transport issues, anesthesia services, chiropractic services, ophthalmology services, clinical laboratories, and sleep clinics. 

While the emphasis on ensuring program compliance in some of these mentioned areas has already been a priority identified in previous Work Plans and/or initiatives taken by the OIG, many of the initiatives identified in this year’s ninety page Work Plan are new. 

Provided above is just a brief highlight of some of the many aspects of healthcare expected to be subject to increased scrutiny and attention by the OIG in 2015.  To illustrate the scope of these new initiatives, the OIG is seeking a $400 million budget for 2015 to carry out its work.  This is up from $300 million that was available to the OIG in 2014.  The OIG clearly intends to justify the $100 million increase in budget, by paying for that amount through its recoveries from its new and existing oversight practices.  For more specific information concerning the OIG’s oversight plans, or on any health care compliance issue, please do not hesitate to contact David Valent, Brian Gannon, or any Healthcare Law Practice Group attorney at Reminger. 

This has been prepared for informational purposes only. It does not contain legal advice or legal opinion and should not be relied upon for individual situations. Nothing herein creates an attorney-client relationship between the Reader and Reminger. The information in this document is subject to change and the Reader should not rely on the statements in this document without first consulting legal counsel.


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