OIG 2011 Work Plan: Old and New Targets

The Office of Inspector General (OIG) released Oct. 1 its annual work plan for the coming year. Not surprisingly, the federal agency said it will review many Medicare Part B issues which have been under the looking glass in years past. With everything that’s been going on this past year with health reform, however, the OIG has plenty of new projects to address as well.

The “Office of Inspector General Work Plan for Fiscal Year 2011” provides brief descriptions of activities the OIG plans to initiate or continue in 2011 with respect to the programs and operations of the U.S. Department of Health and Human Services (HHS), such as the Centers for Medicare & Medicaid Services (CMS).

Ambulatory Surgical Center CASCC

The work plan is all encompassing, but specific to Medicare Part B, the OIG says it will continue to review the following programs and activities:

  • Place of service errors
  • Ambulatory surgical center (ASC) payment system methodology
  • Coding and payment of evaluation and management (E/M) services
  • Billing of portable X-ray suppliers
  • Billing for Medicare outpatient therepy services
  • Sleep testing payments
  • Services and billing patterns in areas highly concentrated with independent diagnostic testing facilities (IDTFs), as well as IDTF compliance
  • Comprehensive outpatient rehabilitation facilities
  • Improper payments for claims not reasonable or necessary
  • Services billed with dates of service after beneficiaries’ date of death

New activities the OIG says it will take on in 2011 include:

  • Medicare payments for Part B imaging services
  • Services performed by clinical social workers
  • Partial hospitalization program services
  • Polysomnography payments
  • Outpatient physical therapy provided by independent physical therapists
  • Diagnostic testing payments
  • Laboratory test unbundling by clinical labs
  • Glycated hemoglobin A1C test payments
  • Trends in laboratory use
  • Lab test payment comparison with other public payers
  • Provider assignment rules compliance
  • Medicare billings with modifier GY
  • Payments for services ordered or referred by excluded providers
  • End-stage renal disease (ESRD) payments
  • Error-prone providers
  • Comprehensive Error Rate Testing (CERT) program

There also are several new and continuing projects planned for durable medical equipment (DME) services and supplies.

Look for a comprehensive review of the OIG work plan in regards to Medicare Part B in an upcoming issue of Coding Edge Magazine.

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