Healthcare providers are finding themselves and their reimbursement claims accountable to more and more auditors as CMS steps up its Medicare and Medicaid auditing activities. And CMS is unlikely to decrease auditing for incorrectly paid claims anytime soon; it too is being held accountable—by the Office of Inspector General (OIG).
In 2010, the OIG plans to review the progress of many Medicare and Medicaid auditing programs, as well as CMS' oversight of several of the programs, according to the 2010 Work Plan, released October 1.
OIG plans to continue its review of how CMS is managing of the RAC program. The OIG also plans to review the number of cases referred to CMS as well as its processing of those referrals and its guidance and training to national RACs on appropriately reporting potential fraud, according to the Work Plan.
The OIG will also continue to monitor the transition from Program Safeguard Contractors to Zone Program Integrity Contractors (ZPIC), entities that are assuming the responsibility for ensuring Medicare claim integrity—a transition that is expected to be completed by March 2010
The Work Plan also indicates that OIG will be watching over Medicaid auditing activities. The OIG will review Medicaid Integrity Program (MIP) efforts "to determine whether states proactively manage overall program risks at the state agency, payment contractor, and provider levels."
In addition, the OIG plans to monitor the following in 2010:
- How states prioritize actions to prevent improper payments
- How providers and/or payment areas are identified for an audit
- Whether improper payments are collected and properly reported to CMS
The OIG also plans to review claims from certain provider types that are "high risk" for submitting improper Medicaid claims. It will identify specific high-risk providers for review based on past Medicaid program work and Payment Error Rate Measurement (PERM) program error rates.
CMS' oversight of the Medicare and Medicaid Data Match Project (Medi-Medi) is also on the OIG's list for review. Medi-Medi seeks to improve the coordination of Medicare and Medicaid program integrity efforts by proactively identifying vulnerabilities or fraud and abuse that may have gone undetected if the data was analyzed separately. According to the Work Plan, the OIG plans to determine whether CMS "is meeting contractual requirements outlined in the Medi-Medi task orders." Task orders were in place for 10 states as of 2007.
Editor's note: For more on ZPIC auditing activities, consider attending the upcoming audio conference, "Zone Program Integrity Contractors: Learn Who They Are, What They Want, and How to Respond to a Review." In addition, for more on Medicaid Integrity auditing, take advantage of the upcoming audio conference, "Medicaid Integrity Contractor Audits: Know What to Expect and How to Prepare."