OIG Releases 2015 Work Plan
November 6, 2014 09:47 AM
The Office of the Inspector General (OIG) recently released its annual work plan. The Work Plan for 2015 specifically addresses issues for home health and hospice.
Overall, the Office of Inspector General (OIG) has identified reducing waste in Medicare Parts A and B and ensuring quality, including in nursing home, hospice care, and home- and community-based care, as top management challenges facing the Department. OIG has focused its efforts on reducing improper payments, improving quality and access, and fostering economical payment policies.
Work planning for fiscal year (FY) 2015 and beyond will consider the following:
Quality of care
Oversight of payment and delivery reform
Protecting an expanding Medicaid program from fraud, waste, and abuse takes on a heightened urgency as the program continues to grow in spending and in the number of people that it serves. The OIG’s continuing and new reviews of Medicaid in fiscal year (FY) 2015 address: prescription drugs; billing, payment, reimbursement, quality, and safety of home health services, community-based care, and other services, equipment, and supplies; State management of Medicaid, information system controls and security, and Medicaid managed care.
There were two issues each specific to hospice and home health providers and one for Medicaid home health agencies. These topics have been part of the OIG’s previous work plans. The OIG’s plan for FY2015 for each of these areas is copied below.
Hospices in assisted living facilities:
“We will review the extent to which hospices serve Medicare beneficiaries who reside in assisted living facilities (ALFs). We will determine the length of stay, levels of care received, and common terminal illnesses of beneficiaries who receive hospice care in ALFs. Pursuant to the ACA, § 3132, CMS must reform the hospice payment system, collect data relevant to revising hospice payments, and develop quality measures for hospices. Our work is intended to provide HHS with information relevant to these requirements. Medicare covers hospice services for eligible beneficiaries under Medicare Part A. (Social Security Act, §1812(a).) Hospice care may be provided to individuals and their families in various settings, including the beneficiary’s place of residence, such as an ALF. ALF residents have the longest lengths of stay in hospice care. MedPAC has said that these long stays bear further monitoring and examination.” OEI; 02-14-00070; expected issue date: FY 2015; ACA.
Hospice general inpatient care:
"We will review the use of hospice general inpatient care. We will assess the appropriateness of hospices’ general inpatient care claims and the content of election statements for hospice beneficiaries who receive general inpatient care. We will also review hospice medical records to address concerns that this level of hospice care is being misused. Hospice care is palliative rather than curative. When a beneficiary elects hospice care, the hospice agency assumes the responsibility for medical care related to the beneficiary’s terminal illness and related conditions. Federal regulations address Medicare conditions of participation (CoP) for hospices. (42 CFR Part 418.) Beneficiaries may revoke their election of hospice care and return to standard Medicare coverage at any time. (42CFR §418.28.)” OEI; 02-10-00491; 02-1000492; expected issue date: FY 2015.
Home health prospective payment system requirements:
“We will review compliance with various aspects of the home health PPS, including the documentation required in support of the claims paid by Medicare. We will determine whether home health claims were paid in accordance with Federal laws and regulations. A prior OIG report found that one in four home health agencies (HHAs) had questionable billing. Further, CMS designated newly enrolling HHAs as high-risk providers, citing their record of fraud, waste, and abuse. Since 2010, nearly $1 billion in improper Medicare payments and fraud has been identified relating to the home health benefit. Home health services include part-time or intermittent skilled nursing care, as well as other skilled care services, such as physical, occupational, and speech therapy; medical social work; and home health aide services.” OAS; W-00-13-35501; W-00-14-35501; various reviews; expected issue date: FY 2015.
Employment of individuals with criminal convictions:
“We will determine the extent to which HHAs employed individuals with criminal convictions. We will also examine the criminal convictions of selected employees with potentially disqualifying convictions. Federal law requires that HHAs comply with all applicable State and local laws and regulations. (Social Security Act, §1891(a)(5), implemented at 42 CFR §484.12(a).) Nearly all States have laws prohibiting certain health-care-related entities from employing individuals with certain types of criminal convictions.” OEI; 07-14-00130; expected issue date: FY 2015.
Screenings of health care workers
“We will review health-screening records of Medicaid home health agency (HHA) health care workers to determine whether they were screened in accordance with Federal and State requirements. Health screenings for home health care workers include vaccinations, such as those for hepatitis and influenza. HHAs provide health care services to Medicaid beneficiaries while the home health care workers are visiting beneficiaries’ homes. HHAs must operate and provide services in compliance with all applicable Federal, State, and local laws and regulations and with accepted standards that apply to personnel providing services within such an agency. (Social Security Act, §1891(a)(5).) The Federal requirements for home health services are found at 42 CFR §§440.70, 441.15, and 441.16 and at 42 CFR Part 484. Other applicable requirements are found in State and local regulations.” OAS; W-00-11-31387; various reviews; expected issue date: FY2015.