The 2016 OIG Work Plan Nursing Homes has released the “Fiscal Year Work Plan, Mid-Year Update 2016” document, which provides an update to the 2016 OIG Work Plan, which was released back in November, 2015. A review of this update gives long term care providers a window into the areas of emphasis for the OIG and its enforcement activities for the remainder of the fiscal year. At 98 pages in length, the report is not exactly a page turner, so I’ll help distill its contents in this post.
By the way, if you’ve read my earlier post, “2016 OIG Work Plan Nursing Home”, you’ll note that there a couple of new items that the OIG has inserted into its activities.
2016 OIG Work Plan Nursing Homes Prospective Payment System
The 2016 OIG work plan nursing homes will examine SNF compliance with the three day stay rule, which specifies that in order to qualify for Medicare part A benefits, a beneficiary must have had at least a three consecutive day stay as an inpatient of a hospital and further, admission to the SNF must have occurred within 30 days of discharge from the hospital. (There are exceptions for “medically appropriate” time periods.) In prior reviews, the OIG notes that they have identified Medicare stays that were not compliant with this requirement. As a footnote, a report on the three day qualifying stay is expected sometime this year.
Response
As the old saying goes, “an ounce of prevention is worth a pound of cure”, so SNF’s should actively work with their admissions and administration personnel to verify that a Medicare beneficiary has a valid qualifying stay. Further, retrospective audits should verify the qualifying stay.
2016 OIG Work Plan Nursing Homes Avoidable Hospitalizations of Medicare and Medicaid Eligible Residents for Urinary Tract Infections
In a study sponsored by the CMS, UTI’s were identified as being associated with potentially avoidable hospitalizations and that UTI’s were preventable and manageable in the nursing home setting. Consequently, the OIG will seek to examine medical records to determine if facilities have in place care plans which reflect the individual needs of the patient including urinary incontinence. It should be noted that the report states, “UTIs acquired during the course of health and medical care could indicate poor quality of care.”
Response
Urinary incontinence patients represent an at risk group for infections and thus, it is a group worthy of close monitoring. Providers should make efforts to ensure that the care plans of this group of patients reflect efforts to address urinary incontinence and further, in instances of UTI’s, the providers take a closer look at their efforts to prevent such occurences.
2016 OIG Work Plan Nursing Homes Background Check for Employees
The 2016 OIG Work Plan Nursing Homes will review efforts by individual states to implement national background checks on employees that have direct access to patients. They will examine the costs associated with the programs, the outcomes and any “unintended consequences” from the program.
Response
While the OIG review occurs on the state levels, providers should ensure that they are complying with their state’s background check program.
2016 OIG Work Plan Nursing Homes State Agency Verification of Deficiency Corrections
The 2016 OIG Work Plan Nursing Homes seeks to determine that states took measures to verify that nursing homes implemented plans of correction for cited deficiencies.
Response
Similar to the background checks, this initiative has no direct impact on SNF’s, however, it would seem logical that such scrutiny on state agencies would cause greater examination of POC’s. As such, it is advisable for providers to insure that they have fully implemented their POC’s.
So there you have it-the 2016 OIG Work Plan Nursing Homes mid-year update in a nutshell. Also, if you’re interested in knowing what the 2016 OIG work plan mid-year update has in store for other healthcare providers, check out our other bog(s): OIG 2016 Work Plan Update mid-year!