The 2015 OIG Work Plan for hospitals and other providers has been released, and once again, hospitals have the dubious distinction of having the most projects (22) devoted to a single provider category in Medicare Part A and Part B. Unlike last year, when half of all projects were new, there are only 2 new projects in the 2015 OIG Work Plan for hospitals – but there are other new projects that actually do cover hospital activities in other provider or program categories..
You can get a quick overview of the 2015 OIG Work Plan, or you can download a copy of the entire document. For those of you who are just looking at an OIG Work Plan for the first time, we also have a useful introduction to the 2015 OIG Work Plan available.
In the meantime, here are the new projects added in the 2015 OIG Work Plan for hospitals.
2015 OIG Work Plan for Hospitals – New projects
Review of hospital wage data used to calculate Medicare payments
Hospitals are expected to have adequate controls in place to accurately report hospital wage data to Medicare. The OIG reviewed this issue and issued a report in 2007. The report stated of 21 hospitals reviewed, 17 overstated their average hourly wage rates, and 4 hospitals understated their rate. CMS made some changes in its methods for calculating this factor, which influences hospital reimbursement under the prospective payment system, and OIG believes there may still be mistakes in the reporting methods.
Long-term care hospitals – adverse events in post-acute care for Medicare beneficiaries
Long-term care hospitals, or LTACs, accounted for $5.4 billion (11%) of Medicare costs for post acute care, third after skilled nursing facilities (SNFs) and independent rehabilitation facilities (IRFs). The number of LTACs in the US has continued to increase, and LTACs take patients much more complex than SNFs, for instance patients with complex wounds, on ventilators or with multiorgan failure.
In its previous study of adverse events in hospitals, the OIG found:
- an estimated 13.1% of patients had an adverse event that resulted serious patient harm,
- an additional 13.5% of Medicare beneficiaries experienced events that resulted in temporary harm, and
- as many as 44% of adverse and temporary harm events were preventable.
The OIG will be attempting to determine similar rates and contributing factors to adverse events for LTACs.
Buried in two other sections of the 2015 OIG Work Plan are projects that may also affect hospitals.
Adoption of Electronic Health Records
As part of the American Recovery and Reinvestment Act of 2009, eligible hospitals (EHs) and eligible professionals (EPs) are eligible for incentive payments for adopting electronic health records (EHRs). Eligible hospitals or professional who claim such incentive payments are subject to repayment if it is found they did not meet the criteria for receiving them. The OIG will review Medicare payment data from 2011, the first year in which incentive payments were made, to identify EHs or EPs that should not have received payments because they did not meet meaningful use criteria. The OIG project will review payments from Medicare and Medicaid.
Hospitals’ electronic health record system contingency plans
As part of addressing the HIPAA Security Rule, hospitals are required to conduct a HIPAA Risk Assessment and develop policies and procedures for addressing the requirements of the HIPAA Security Rule. One section of the Security Rule requires health care organizations that create, use, maintain or store electronic Protected Health Information (eHPI), to develop policies and procedures for responding to an emergency or other occurrence that damages systems that contain ePHI. The OIG will attempt to determine the extent to which hospitals comply with this provision of the HIPAA Security Rule. It should be noted that performing a HIPAA Risk Assessment is one of the meaningful use criteria hospitals must meet to qualify for meaningful use incentive payments.
2015 OIG Work Plan for Hospitals – Continuing projects
There are still over 20 other projects the 2015 OIG Work Plan for hospitals that are continued from prior years. They fall into categories ranging from hospital-related policies and procedures to billing and payments to quality of care and safety. Many have direct financial implications for hospitals found not in compliance with specific Medicare or Medicaid regulations. Most hospitals with effective compliance plans can and should review all of the projects in the 2015 OIG Work Plan for hospitals, and use it as a guide for focusing at least some of their internal compliance auditing activities.