OIG Work Plan 2013 – Medical Equipment and Supplies

If you are not aware, every year the OIG ( Office of Inspector General) produces a report on what they plan to audit and review for the upcoming year. The new report does not take past items of interest off the table.

Here are some highlights for medical equipment suppliers:
1. They will review Accreditation Organization and their process for approving providers.
2. Service code modifier KX indicates the patient meets the medical criteria and upon request their is information that supports the medical need of the patient. In audits, they have found that providers have little to no documentation to support medical need. Make sure you read the medical records you obtain from physicians ordering services to ensure they include documentation that supports services you have provided.
3. In audits of lower limb prostheses, they have found in 267 providers audited no history of the patient having a lower limb amputation. I would recommend if you are providing prostheses, you obtain where the amputation was done. Medicare may not have documentation because it was not paid for by Medicare or change of physicians.
4. It appears they will be looking at reimbursement for several items and comparing it to other payor sources to see if they can reduce their reimbursement or frequency for items such as erect aids, back orthoses, parenteral nutrition, and CPAP (frequency).
5. Diabetic supplies will be reviewed for: a) see if medical records corroborate the IDDM as compared to NIDDM (making sure IDDM isn’t submitted just to bill for more supplies), b) multiple supplies, c) make sure supplies are not auto shipped, d) patients requests refill, e) the quantity of supplies left is documented at the time of request for refill, f) compares supplies provided to the competitive bid areas, g) see if “non-mail” order supplies were actually mailed, if they are in competitive bid areas, and h) IF supplies are mailed but KL not applies to indicate so the provider receives a higher rate of reimbursement.

If you have not started your compliance program audit and risk assessment protocol, these are some key areas to look at to reduce your business risk. Ask physicians to provide copies of medical records at the time of the order.

Remember, to look at the OIG Work Plan from 2012.  I outlined hightlights last year that you really need to review if you did not and continue to include those moving forward.

You may find the the OIG Work Plan details at https://oig.hhs.gov/reports-and-publications/workplan/index.asp and see Medicare Part I for Parts A & B.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller is Certified in Healthcare Compliance.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

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Training for Compliance & HIPAA Privacy and Security

Medical Auditing Solutions LLC launched the Compliance University in September 2011 and is please to announce that for 6 of the programs we have received Continuing Education Credits by Texas Occupational Therapist Association (TOTA) (15 hours) , Texas Board of Professional Counselors (6 hours minimum) , and BOC USA (9.5 hours).

What are you waiting for?  You have to train staff annually on compliance program requirements, fraud and abuse, billing,privacy and security. You have to be able to prove this training was given.  Does your staff have time to develop, track and update?  Did you know the OIG is auditing for these policies, training, sanction checks, and more in 2013 for providers that $5M in annual collections from Medicaid programs?  Did you know that OCR is auditing all types and sizes of healthcare providers from HIPAA privacy and security in 2012 and years to come?  Did you know the state inspector generals and health and human services will be auditing for these policies as well?  We can help you will all aspects of your compliance and HIPAA programs.

These requirements apply to all healthcare providers, DME, home health, physicians, and dental providers.  The size of your business does not matter for HIPAA.  As of  February 2013 for Compliance applies to all as well.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

OIG Work Plan 2012

I participated in a call on Thursday January 19, 2012, on the OIG Work Plan for 2012.  Please reference the link for the full OIG Work Plan spelled out by provider type.  Many items on the Work Plan never change but there were a few points I felt important to draw your attention to for risk management purposes.  Here are a few notes I made because I think the audit risk is high since the result can be subjective:

1.  Outpatient Observation Billing

2.  Critical Access Hospitals:

A.  Distance to nearest, non-critical access hospital

B.  Herceptin and other Chemo Drug quantity

3.  Hospice because 82% of patients do not meet criteria to be admitted to hospice.

4.  Incident to Services by non-qualified personnel.  Even Blue Cross and Blue Shield is recouping and extrapolating on commercial claims for mid-level practitioner billing.  Make sure modifier is used when appropriate and the mid-level meets the licensing requirements to provide the services billed.

5.  Off Label Prescriptions.  Physicians ordering a drug that is approved for Diagnosis A but the drug is used for diagnosis B.

6.  Home Health-but not specific because they are going to review 2010 billing before they decide.

7.  Dialysis and ESRD Drug costs.  What is the drug cost to the provider versus the reimbursement.

8.  Contracts providers have with other providers/facilities.  Make sure you have a health care attorney to review the contract before executing because the health care attorneys are familiar with the Stark and Anti-Kickback provisions which typically the corporate business attorney does not have to consider.

9.  Checking employees, vendors, and providers against Sanction Databases MONTHLY.  You may find the federal links on my website.  The states have their own links.

10.  NY Medicaid reduced the annual revenues to $500K in Medicaid/Medicaid HMO/Managed Care Organizations (MCO) funds for compliance program requirement.

11.  Compliance Program Requirement under Federal Deficit Reduction Act that required all healthcare providers to have a compliance program in place by 2007 if their annual collected revenue of State reimbursement was $5M or more.  This would include Medicaid and respective Medicaid HMO or MCO.

12.  As of 2013 a healthcare compliance program is required for all providers billing Federal or State plans no matter what the annual billing revenue may be.  This would include dental practices because they bill Medicaid!

13.  Overpayments must be disclosed and refunded within 60 days of identification that it is an overpayment.  Failure to refund this money can result in “False Claims” charges and penalties.  Ensure you have someone that is accountable for working your credit balance reports monthly.  Keep documentation of these reviews and refunds issued as a result in a manner that can easily be explained and found.

The OIG Work Plan can be used to determine risk analysis, structure audit plans, and determine growth opportunities.

Do you have a Healthcare Compliance Program?

Do you review the OIG Work Plan Annually?

What else do you review to determine your audit plan?

We can help you analyze the status of your healthcare compliance program and ensure you have focused on the correct risks for your business model.  We are the compliance expert with a vast history and a cost effective way to ensure your compliance program is operating and managing your risk.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.