Amy F. Lerman, Associate in the Health Care and Life Sciences practice, in the Washington, DC, office, co-authored a Member Briefing for American Health Lawyers Association’s Fraud and Abuse Practice Group, titled “Summary of OIG’s 2015 Work Plan.” (Read the full version — subscription required.)
Following is a summary:
The Member Briefing pertains to the U.S. Department of Health and Human Services Office of Inspector General’s (OIG’s) Work Plan for Fiscal Year (FY) 2015 (Work Plan). The Work Plan is a blueprint of new and ongoing initiatives that OIG plans to pursue during the current fiscal year.
For FY 2015 and beyond, OIG intends to focus on emerging payment, eligibility, management, and information technology systems security vulnerabilities in the Affordable Care Act programs, such as the health insurance marketplace. OIG stated that it would also focus on the efficiency and effectiveness of payment policies in inpatient and outpatient settings, for prescription drugs, and in managed care.
The Work Plan signals that OIG will focus on: (1) identifying clinical laboratories that routinely submit improper Medicare claims; (2) reviewing the rate of and reasons for transfers from group homes or nursing facilities to emergency departments as a potential indicator of poor quality; (3) identifying Medicaid Managed Care Organization payments made on behalf of deceased or ineligible beneficiaries; and (4) assessing the extent to which hospitals comply with the contingency planning requirements of the Health Insurance Portability and Accountability Act.