This edition of the Work Plan, effective as of May 2015, describes OIG audits, evaluations, and certain legal and investigative initiatives that are ongoing. In response to adjustments made to the Work Plan, this mid-year update removes items that have been completed, postponed, or canceled and includes new items that have been started since October 2014. The word “new” before a project title indicates that the project did not appear in the previous Work Plan. For each project, they include the subject, primary objective, and criteria related to the topic. At the end of each description, they provide the internal identification code for the review (if a number has been assigned) and the year in which they expect one or more reports to be issued as a result of the review.
The updates that are included are those that we feel relate to the McKesson Business Performance Services potential business involvement and therefore, are not inclusive of all new updates.
OIG will periodically update its online Work Plan. Check for updates or read the full report (PDF, 3.5 MB).
Medicare Part A and Part B
Hospitals - Hospitals—Billing and Payments
- NEW Intensity-modulated radiation therapy
“We will review Medicare outpatient payments for intensity-modulated radiation therapy (IMRT) to determine whether the payments were made in accordance with Federal rules and regulations.
IMRT is an advanced mode of high-precision radiotherapy that uses computer-controlled linear accelerators to deliver precise radiation doses to a malignant tumor or specific areas within the tumor. Prior OIG reviews have identified hospitals that have incorrectly billed for IMRT services. To be processed correctly and promptly, a bill must be completed accurately. (CMS’s Medicare Claims Processing Manual, Pub. No. 100-04, ch. 1, § 188.8.131.52.) In addition, certain services should not be billed when they are performed as part of developing an IMRT plan. (CMS’s Medicare Claims Processing Manual, Pub. No. 100-04, ch. 4, § 200.3.2) (OAS; W-00-15-35740; various reviews; expected issue date: FY 2016)”1
Hospitals - Hospitals—Quality of Care and Safety
- NEW Hospital preparedness and response to high-risk infectious diseases
“We will describe hospitals’ efforts to prepare for the possibility of public health emergencies resulting from infectious diseases. Several HHS agencies, including the Centers for Disease Control and Prevention (CDC), the Office of the Assistant Secretary for Preparedness and Response (ASPR), and CMS provide resources, (i.e., guidance and support) for hospitals as they prepare. Additionally, we will determine hospital use of HHS resources and identify lessons learned through recent experiences with pandemic or highly-contagious diseases, such as Ebola. Prior OIG work identified shortcomings in such areas as community preparedness for a pandemic (2009) and hospital preparedness for a natural disaster (i.e., Super storm Sandy, 2013). (OEI; 06-15-00230; expected issue date: FY 2016)”2
Medical Equipment and Supplies - Equipment and Supplies—Quality of Care and Safety
- NEW Access to durable medical equipment in competitive bidding areas
"We will determine the effects of the competitive bidding program on Medicare beneficiaries' access to certain types of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) subject to competitive bidding. In an effort to reduce waste, the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) updated Medicare’s payment system for certain DMEPOS from a fee schedule to a competitive bidding program. Under this program, DMEPOS suppliers compete on price to supply to particular geographic areas. Anecdotal reports allege that competitive bidding has led to reduced access to DME and, in turn, compromised the quality of care beneficiaries receive. (OEI; 01-15-00040; expected issue date: FY 2016)”3
Other Providers and Suppliers - Other Providers—Billing and Payments
- NEW Annual analysis of Medicare clinical laboratory payments
“We will analyze Medicare payments for clinical diagnostic laboratory tests, including the top 25 clinical diagnostic laboratory tests by Medicare expenditures in 2014. Previous OIG work has found that Medicare pays more than other insurers for certain high-volume and high-expenditure laboratory tests. Section 216 of the Protecting Access to Medicare Act of 2014 requires new Medicare payment rates for laboratory tests beginning in 2017 based on private payer rates and establishes processes for determining initial payments for new laboratory tests. Pursuant to a requirement of the Protecting Access to Medicare Act, OIG will conduct an annual analysis and monitor Medicare expenditures and the new payment system for laboratory tests. (OEI; 09-15-00210; expected issue date: FY 2016)”4
- NEW Inpatient rehabilitation facility payment system requirements
“We [OIG] will review compliance with various aspects of the IRF PPS, including the documentation required in support of the claims paid by Medicare. We will determine whether IRF claims were paid in accordance with Federal laws and regulations. IRFs provide rehabilitation for patients recovering from illness and surgery who require an inpatient hospital-based interdisciplinary rehabilitation program, supervised by a rehabilitation physician. Effective for discharges on or after January 1, 2010, all documentation and coverage requirements specified in 42 CFR § 412.622(a)(3) (4) and (5) must be met to ensure that IRF care is reasonable and necessary under the Social Security Act (the Act), § 1862(a)(1)(A). (74 Fed. Reg. 39762, 39788). (OAS; W-00-15-35730; various reviews; expected issue date: FY 2016)”5
Other Part A and Part B Program Management Issues
- NEW Use of electronic health records to support care coordination through ACOs
"We will review the extent that providers participating in ACOs in the Medicare Shared Savings Program use electronic health records (EHRs) to exchange health information to achieve their care coordination goals. We will also assess providers’ use of EHRs to identify best practices and possible challenges in their progression toward interoperability (the extent that information systems can exchange data and have the ability to interpret those shared data). The Medicare Shared Savings Program promotes accountability of hospitals, physicians, and other providers for a patient population, coordinates items and services, and encourages investment in infrastructure and redesigned care processes for high quality and efficient service delivery. (ACA, § 3022.) OEI; 00-00-00000; expected issue date: FY 2016.”6
Medicare Part C and Part D
Part D Billing and Payments
- NEW Billing trends for Part D drugs and commonly abused opioids
“We will describe trends in Part D billing from 2006 to 2014, including changes in billing for commonly used opioid drugs. We will also describe billing trends associated with pharmacies in 2014. Drug diversion and prescription drug abuse are growing problems. CDC considers prescription drug abuse to be an epidemic, and deaths from drug overdose are now one of the leading causes of accidental death. OIG is also seeing a significant increase in Part D fraud and has a wide portfolio of work involving pharmaceutical matters, including prescription drug diversion. (OEI; 02-15-00190; expected issue date: FY 2015).”7
Medicaid Prescription Drug Reviews
Medicaid Information System Controls and Security
Controls to Ensure the Security of Medicaid Systems and Information
- NEW Completeness of data in Transformed MedicaidStatistical Information System: early implementation
“We will determine whether States are submitting complete Transformed Medicaid Statistical Information System (T-MSIS) data. T-MSIS is designed to be a detailed national database of Medicaid and Children's Health Insurance Program information to cover a broad range of user needs, including program integrity. It is a continuation of CMS’s past attempts to improve nationally available Medicaid data after OIG and others found that the data were not complete, accurate, or timely. (OEI; 05-15-00050; expected issue date: FY 2016)”8
Centers for Disease Control and Prevention
- NEW CDC—Award process for Ebola preparedness and response funding
“We will review CDC’s process for awarding funding for Ebola preparedness and response activities to ensure compliance with applicable laws, regulations, and departmental guidance. The review will include awards made to foreign and domestic recipients. Previous OIG reviews have noted possible deficiencies in CDC’s award process, such as conflicting, missing, or inaccurate information in the Funding Opportunity Announcement and the Notice of Award. The Grants Policy Directive, Part 2, § 04, specifies the process for competitive review, ranking applications, approval of applications, and award policy. The Consolidated and Further Continuing Appropriations Act, 2015, enacted on December 9, 2014, provided $2.7 billion in emergency funding to HHS for Ebola preparedness and response activities. Of this, $1.771 billion was allocated to CDC to prevent, prepare for, and respond to Ebola domestically and internationally (OAS; W-00-15-58300; expected issue date: FY 2016.”9
Read the full McKesson summary (PDF, 196 KB).