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OIG Releases 2011 Work Plan

Michael Iarrobino, CPC-A, for HealthLeaders Media, October 5, 2010

Medical devices, radiation therapy quality and safety, and an expanded focus on the three- and one-day payment windows are among the highlights of the Office of Inspector General's (OIG) fiscal year (FY) 2011 Work Plan. The plan, posted October 1, introduces some new focus areas but largely continues the OIG’s stance from 2010.

"What we're really looking at are four or five really brand new issues," says Stephen Miller, JD, chief compliance and privacy officer for Trenton, NJ–based Capital Health System, Inc. This should make the work easier for hospital compliance officers, who often target new topics as ones for which they must develop additional auditing tools and strategies.

New topics address quality, billing concerns
Among entrants to the OIG list for 2011, Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc., in Marblehead, MA, highlights the following:

  • Brachytherapy reimbursement
  • Replacement of devices received at no cost or reduced cost
  • Safety and quality of intensity-modulated radiation therapy (IMRT)
  • Safety and quality of image-guided radiation therapy (IGRT)

"Any time the OIG adds new issues, such as medical devices, brachytherapy, IMRT and IGRT, facilities who provide these services should sit up and take notice," Mackaman says.

Miller notes the focus on quality and safety with IMRT and IGRT. Their inclusion on the list shows the OIG's responsiveness to the headlines, he says. Media reports circulated earlier this year in outlets such as The New York Times regarding quality concerns with these types of procedures, especially in connection with Veterans Affairs facilities.

From a billing perspective, Mackaman flags medical device replacement as an area for hospital attention. "Since the medical devices replacement issue can be a difficult billing procedure to comply with, facilities should certainly do an in-depth process audit in this area," she says. For information regarding proper reporting of reduced- or no-cost devices, Mackaman suggests reviewing 73 Federal Register 68631–68632 and the Medicare Claims Processing Manual, Chapter 4, sections 61.3.1–61.3.3.

This year’s Work Plan omits previous stalwarts like the Emergency Medical Treatment and Labor Act (EMTALA) and coding and documentation under the MS-DRG system. In the case of EMTALA, Miller says, the OIG may believe that CMS is sufficiently scrutinizing hospitals.

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