December 2011

HHS Office of the Inspector General Releases 2012 Work Plan

A Polsinelli Shughart Update

The U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) issued its FY 2012 Work Plan recently, which outlines the new and ongoing reviews and activities that the OIG plans to pursue with respect to HHS programs and operations. The Work Plan highlights special areas of interest to the OIG, which often translate into increased compliance risks for providers, including:

• Accuracy of Present-on-Admission Indicators Submitted on Medicare Claims
• Medicare Inpatient and Outpatient Payments to Acute Care Hospitals
• Hospital Inpatient Outlier Payments: Trends and Hospital Characteristics
• Medicare’s Reconciliation of Outlier Payments
• Inpatient Rehabilitation Facilities
• Critical Access Hospitals
• Physicians & Other Suppliers: High Cumulative Part B Payments
• Physicians: Place of Service Errors
• Physicians: Incident to Services
• Hospital Claims with High or Excessive Payments
• Acute-Care Hospital Inpatient Transfers to Inpatient Hospice Care
• Medicare Outpatient Dental Claims

Click here for more detail on the key areas of interest in the work plan.

What You Should Do Now

We recommend that our clients take the following actions:

1. Review these highlighted topics and determine which are applicable to your organization
2. Review internal monitoring processes, such as Quality Assurance reviews, to determine if the identified areas of interest are being properly reviewed
3. Initiate or update the review process for these identified areas of interest to ensure that they are being properly maintained

We will provide additional guidance on other areas of interest from the Work Plan in future alerts.

For More Information

If you have questions regarding this regulatory update or any other issues, please contact:

• Matthew J. Murer | 312.873.3603 | mmurer@polsinelli.com
• Daniel S. Reinberg | 312.873.3636 | dreinberg@polsinelli.com
• Jay M. Howard | 816.360.4202 | jhoward@polsinelli.com
• T. Jeffrey Fitzgerald | 303.583.8205 | jfitzgerald@polsinelli.com
• Joan B. Killgore | 314.889.7008 | jkillgore@polsinelli.com
• Meredith A. Duncan | 312.873.3602 | mduncan@polsinelli.com
• Joseph T. Van Leer | 312.873.3665 | jvanleer@polsinelli.com

ABOUT POLSINELLI SHUGHART PC:

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