Providers may choose to not enter into corporate integrity agreements (CIAs) after they have settled fraud cases. The OIG has decided to target these entities according to the OIG Work Plan for 2012.

Click View Recording to see a replay of the "Understanding Exclusions and the Need to Undertake Regular Sanction Screening" Webinar

The FY 2011 Office of the Inspector General Work Plan contains two issues that professional fee coders should be concerned about. Correct coding of E/M services based on the guidelines and E/M services during global surgery periods are ongoing issues.

We are pleased to announce that the question sets for the 2011 OIG Work Plan for Hospitals are now available! 

The new question sets are:

• Non-IPPS Hospital Payments for Nonphysician Outpatient Services
• Medicare Excessive Payments
• Hospital Occupational Mix Data Used to Calculate Inpatient Hospital Wage Indexes
• Early Implementation of Medicare’s Policy for Hospital-Acquired Conditions
• Hospital Reporting for Adverse Events
• Hospital Reporting for Restraint and Seclusion Related Deaths
• Medicare Brachytherapy Reimbursement
• Hospitals Compliance With Medicare CoP Intensity-Modulated and Image-Guided Radiation Therapy Services
• Medicare Inpatient and Outpatient Hospital Claims for Replacement of Medical Device
• Hospital Inpatient Outlier Payments

For all of you out there who were waiting with baited breath (oh, wait, that was just me)...the Office of the Inspector General released the 2011 Work Plan.  But, I have noticed a couple of things right off the bat and wanted to share.  First, it is longer than last year!  This may not mean a lot, but for those of us who sit and read the whole document, it is significant.  Last year it was 128 pages, this year it is 159 -- 31 more pages.  Sigh.  Second, in addition to being able to download the entire .pdf, the OIG has also provided .pdf's to the individual Wor

The Office of Inspector General (OIG) found that public disclosure of information about adverse events was limited, according to its review of 17 state adverse event report systems, eight Patient Safety Organizations overseen by the Agency for Healthcare Research and Quality (AHRQ), and the Centers for Medicare and Medicaid Services (CMS).

Are we ready for the impending flu season?  What about an influenza pandemic?  The OIG recently released a duo of reports addressing preparedness for an influenza pandemic.  In one of the reports, the OIG examined the extent to which states and localities have prepared for a medical surge in response to an influenza pandemic and whether they have conducted and documented exercises that test their medical surge

In a report issued on August 5, 2009, the OIG examined days that Medicare allows more than 24 hours of services billed by a single physician and sought to identify the services physicians bill to Medicare but do not perform personally and the qualifications of nonphysicians performing "Incident To" services.  The OIG found that: 

Medicare's postacute care transfer policy pays full DRG payments to hospitals for patients discharged to home.  Medicare pays hospitals that transfer patients to postacute care settings (e.g., skilled nursing, home health care) a per diem rate.  In a recent audit report, the OIG found that of 150 claims sampled, 92 of them were improperly coded as discharges to home rather than transfers to postacute care settings.  The OIG noted that multiple prior reports have found that hospitals are not complying with the postacute transfer policy.  Perhaps it is time for your hospital to audit its compliance with the policy?  See OIG Report A-04-07-03035 (February 2009).

On February 17, 2009, the American Hospital Association, Association of American Medical Colleges and Federation of American Hospitals submitted a comment letter to CMS recommending two new exceptions to the physician self-referral law - exceptions for incentive payment and shared-savings programs.  At the same time, the hospital groups also submitted a letter to the OIG asking for formal withdrawal of the 1999 Special Bulletin regarding gainsharing arrangements.  The letters address CMS final rule with comment