The HHS OIG released its Work Plan for FY 2014 three months ago and is hard at work investigating the issues highlighted in its annual publication. The OIG’s annual Work Plan lists current and new projects it will address during 2014, and is an excellent source for healthcare facilities to use in identifying potential compliance risk areas. The Work Plan has a number of items that impact children’s hospitals. Whether you immediately added these issues to your organization’s list of potential risk areas or still haven’t had the opportunity to review this year’s Work Plan, we recommend that you do not lose sight of these issues.
We have listed below some of the Work Plan items that are most likely to impact children’s hospitals:
1. Duplicate GME Payments.
This year’s Work Plan cites duplicate Graduate Medical Education (GME) payments as an issue for hospitals. While children’s hospitals are generally paid under the Children’s Hospital Graduate Medical Education (CHGME) program, the two programs mirror each other and payments under the CHGME will likely be scrutinized in the same way as GME payments. The OIG plans to review provider data from CMS’s Intern and Resident Information System (IRIS) to determine whether hospitals received duplicate or excessive GME payments. The primary purpose of IRIS is to prevent duplicate GME payments, which can happen if a single resident is counted as more than one FTE. While this is not a new area for the OIG to examine, this is a complex area and children’s hospitals would be wise to make sure all GME payments are appropriate.
2. Indirect GME Payments.
The work report lists a second issue related to GME payments. This one is related to payments for Indirect GME expenses. The OIG wants to ensure that hospitals have calculated these payments properly. Teaching hospitals receive higher payments to reflect the higher cost of providing care in a teaching hospital, and the payments are based on the ratio of resident FTEs to available beds. This issue is new to the 2014 Work Plan.
3. Oversight of Hospital Privileging.
The OIG believes that robust hospital privileging programs contribute to patient safety. As such, this year it is adding hospital privileging to its list of issues to assess. As telehealth and telemedicine continue to be growth areas for many children’s hospitals, the process of privileging remote physicians is fraught with potential compliance issues. Whether physicians at your hospital are providing telehealth or telemedicine services or you are on the receiving end, you will want to review your privileging procedures for any telehealth or telemedicine providers.
4. Use of Atypical Antipsychotic Drugs.
The OIG will continue looking at claims for atypical antipsychotic drugs prescribed to patients 18 years old and younger and determine the extent to which they were for uses and indications not listed in an approved drug compendium. The OIG will also examine dosage, duration, indications for use, monitoring, side effects, reactions, and patient age in an effort to identify concerning practices.
5. Inappropriate Billing for Dental Services.
If your facility provides dental services to Medicaid beneficiaries, you may want to review your claims process for those services. The Work Report indicates the OIG will continue to review claims to determine whether States have properly claimed Federal reimbursement, but it does not describe any specific issues they are looking for. Federal regulations define “dental services” as diagnostic, preventative, or corrective procedures provided by or under the supervision of a dentist.
It is important for facilities to take the time to asses these areas and correct any problems. Doing this will not only provide direct benefits in the form of fewer reimbursement and compliance issues, but it will also provide evidence, should you need it, that your facility has an active and effective compliance program.