How Healthcare Employers Can Prepare for the The OIG’s Fiscal Year 2015 Work Plan

At the end of October, The United States Department of Health and Human Services (HHS) Office of Inspector General (OIG) released its Fiscal Year Work Plan outlining new and ongoing activities that the department will pursue in 2015.

The OIG primarily exists to monitor and audit spending and practices by agencies and individuals that bill Medicare, Medicaid and other federal healthcare programs. One of the main ways the OIG performs this service is by maintaining a List of Excluded Individuals/Entities (LEIE) who are banned from participation in Federal healthcare.

Individuals and entities may be excluded by the OIG for illegal activity like fraud, patient neglect or prescription drug misuse, among other things. Employers who bill Federal healthcare services are required to screen employees for OIG exclusion and report any excluded employees to the OIG. The OIG will then withhold payment for services and products rendered by that individual.

The OIG Fiscal Year 2015 Work Plan included several announcements that may affect this particular function of the OIG.

The OIG reasserted its commitment to protect Medicaid from fraud, waste and abuse, which will only become more urgent as the program expands. They’ll also more closely investigate state claims for drug rebates and federal reimbursement.

Additionally, the office will also closely scrutinize community-based care and adult day care service providers to make sure they comply with federal and state requirements. They’ll also be cracking down on home health agencies that don’t properly screen their workers for OIG compliance.

Medical equipment, supplies, transportation and managed care will also be more closely monitored to make sure that state OIGs and other organizations aren’t abusing the system, which could land them on the exclusion list.

The harm done to patients in long-term-care hospitals will be investigated, and the OIG will analyze what factors lead to patient harm and abuse (which can also be grounds for an OIG exclusion).

Special attention will be paid to reviewing billing practices and claims that may be less than genuine, like those made by independent clinical laboratories trying to recover from overpayments, and individuals who use billed services inappropriately.

To prepare for the OIG plan for 2015, organizations that bill federal healthcare should screen employees for OIG compliance and make sure billing practices are in line with OIG standards.

“Making sure that you stay ahead of the curve and on top of your exclusion checks is an important part of your compliance package, especially when the OIG makes changes,” says Jeff Josefovic, Director of Operations at Streamline Verify.