OIG 2013 Work Plan Targets New Areas of Investigation - Hospices

Author: K. Jill Osmars

The Office of Inspector General (OIG) is the arm of the federal government that is charged with identifying, preventing and investigating fraud and abuse in Medicare and other federal programs.  Each year, the OIG publishes its Work Plan, which identifies the audits and investigations it intends to pursue during the year.

The OIG is authorized to impose monetary penalties against physicians and physician groups and may exclude individuals and medical groups from Medicare.  For these reasons, it is important for physicians to be aware of new trends in OIG enforcement activities as part of their compliance plans.

The 2013 Work Plan was published recently and identifies the following areas of interest:

Marketing Practices to Skilled Nursing Facilities:  The OIG will review marketing materials and practices by hospices to determine if they are overly aggressive or incorrectly define the Medicare hospice benefit and eligibility criteria.  The focus will be on potentially inappropriate enrollment and compensation.

Financial Relationships with Nursing Facilities: The OIG will focus its review on “hospices that have a high percentage of their beneficiaries in nursing facilities.”  In recent reports, the OIG notes that 82 percent of hospice claims for nursing facility beneficiaries did not meet Medicare coverage requirements.

General Inpatient Care: The OIG will review both hospice claims and medical records to determine if this level of hospice care is being misused.

Hospices are well advised to update their compliance plans and compliance programs to ensure the issues identified in the OIG’s 2013 Work Plan are being addressed.  If you have any compliance questions, please contact DSMW for review and advice.



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