As of June 2017, the Office of Inspector General (OIG) began providing updates to their Work Plan on a monthly basis. This will help compliance professionals update their plan or make sure they are continuing to focus on the most current OIG priority areas. The online updates will allow direct access to providers and other visitors.
A few topics that stood out to us for July’s OIG Work Plan are the following:
- Medicaid Claims for Opioid Treatment Program Services
- Review of Medicare Payments for Telehealth Services
- Assertive Community Treatment Program
- Nationwide Medicare Electronic Health Record Incentive Payments to Hospitals
- Consumer-Directed Personal Assistance Program
We have highlighted only a few of the additions; however, each one is important to take a few minutes to review. Find the full list of Recently Added Items on OIG’s site. Let’s walk through some of these updates and identify how to address each item within your compliance program.
Medicaid Claims for Opioid Treatment Program Services
The opioid epidemic remains a top concern for OIG and the general public. Many treatment programs throughout the country are paid via Medicaid dollars for OTP (Opioid Treatment Programs). This update addresses whether or not State agencies are living up to both State and Federal requirements for Medicaid reimbursement.
See the full update here.
Review of Medicare Payments for Telehealth Services
As the tech boom continues to evolve, more telehealth applications are being used for consultations and appointments. These scenarios create a need to address the specifics of care mechanisms, particularly how they relate to Medicare payments. These services are having a very positive impact on rural areas where healthcare access is limited. Certain requirements must be met for each video conference between beneficiaries and practitioners for Medicare to be applied.
Read the latest clarification for Medicare Part B and expenses covered here.
Assertive Community Treatment Program
Are you familiar with ACT? This program helps address severe cases of mental illness with a communal effort based on peer support and guidance. There are quite a few services that are included in the program, and OIG has determined a few areas of concern with regards to rate-setting. In some cases, Medicaid allocation is not in compliance with State and Federal regulations. OIG determines whether these payment rates are consistent with a few essential requirements.
Take a look at how OIG defines Assertive Community Treatment service requirements here.
Nationwide Medicare Electronic Health Record Incentive Payments to Hospitals
In an effort to continue to promote EHR implementation, hospitals have been given the opportunity to receive incentive payments over a five year period. Between 2001 and December 31, 2016, OIG reports reveal some serious deficiencies in payment and oversight of the EHR program.
Find out more details about obstacles CMS faces in regards to EHR here.
Consumer-Directed Personal Assistance Program
Home health services remain a top priority for OIG, especially regarding uncovering fraudulent behavior and unfair service provided. The Medicaid Consumer-Directed Personal Assistant Programs help provide alternative options for care including family members, friends, or guardians directing particular types of in-home care.
The problem(s) lie in possible ineligible parties or persons that may be receiving Medicaid payments which do not comply with Federal and State regulations. While personalizing the selection of caregivers is a positive experience, these consumer-directed efforts must be in accordance with regulations.
Read more about this latest update here.
What are your thoughts on updates to OIG’s Work Plan for July? Are there any other OIG updates that you found particularly interesting? Let us know in the comments below!
Written by Michael Rosen, ESQ
Michael brings over 20 years of experience founding and leading risk mitigation businesses, receiving numerous accolades such as: Inc Magazine's Inc 500 Award and Nashville Chamber of Commerce Small Business of the Year.