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OIG Releases 2015 Work Plan

The OIG's 2015 Work Plan has been posted to its website and is available for review by providers. The Work Plan describes the activities and investigations planned by the OIG for 2015 and breaks down those plans by provider type. For long-term and post-acute providers, pertinent highlights include:

  • The OIG plans to review Medicare Part A billing by skilled nursing facilities (SNFs) and describe changes in SNF billing practices from 2011 to 2013. Prior OIG work found that SNFs increasingly billed for the highest level of therapy even though beneficiary characteristics remained largely unchanged.
  • The OIG will monitor Part B billing for abuse during non-Part A stays to ensure that no excessive services are provided. The OIG will identify questionable billing patterns associated with nursing homes and Medicare providers for Part B services provided to nursing home residents during stays not paid under Part A.
  • The OIG is concerned that hospitalizations of nursing home residents are costly to Medicare and may indicate quality-of-care problems in nursing homes. The OIG will determine the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting.

The Work Plan addresses numerous other issues to be reviewed by the OIG, and we encourage all providers to study the 2015 Work Plan closely. If you have any questions regarding its contents or how you can prepare your organization to address the compliance issues raised by the OIG, please do not hesitate to contact David Marshall at dmarshall@ldylaw.com

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