The HHS Office of Inspector General (OIG) has issued its FY 2017 Work Plan, which lays out the OIG's current audit, evaluation, and other legal and investigative priorities. The largest number of new initiatives by far target Medicare Parts A and B, including reviews focusing on the following:

  • Skilled nursing facility (SNF) issues, including:  complaint investigations; unreported incidents of potential abuse and neglect; use of the adverse event screening tool; durable medical equipment provided during non-Part A nursing home stays; and whether SNF documentation meets requirements for each resource utilization group.
  • Various provider payment policies, covering: inpatient psychiatric facilities, transitional care management, chronic care management, potential savings from inflation-based Medicare Part B drug rebates, and implementation of the physician Quality Payment Program.
  • Compliance with federal regulations, involving hospice services, hyperbaric oxygen therapy services, and positive airway pressure device supplies.
  • Other policy reviews, including such topics as: inpatient rehabilitation hospital patients not suited for intensive therapy, frequency of nurse on-site hospice visits, drug waste of single use vial drugs, payments for service dates after individuals' dates of death, and financial interests reported under the Open Payments program.

New Medicare Part C and D reviews will address: Medicare Part C and D payments for service dates after individuals' dates of death; the extent of denied care in Medicare Advantage; Medicare Part D rebates related to drugs dispensed by 340B pharmacies; and Part B billing for compounded topical drugs.

The OIG also plans a number of new Medicaid reviews, involving such issues as Medicaid managed care organization drug claims and compliance with hold-harmless requirements; delivery system reform incentive payments; Medicaid accountable care; third-party liability payment collections; Medicaid overpayment reporting and collections; and health-care-related taxes. OIG review subjects also will include programs administered by the Food and Drug Administration, the National Institutes of Health, and various other HHS-related reviews.

This article is presented for informational purposes only and is not intended to constitute legal advice.