2017 OIG Work Plan

Today, the Office of Inspector General (OIG) published its 2017 Work Plan which outlines new, ongoing, and upcoming reviews/activities that the OIG is currently working on or plans to pursue.  We have summarized some of the important issues related to hospitals and physicians below.





Hyperbaric Oxygen Therapy


Focus on whether services are provided for covered conditions, documentation supports treatments, and whether treatments were provided in excess of what was medically necessary.

Incorrect Claimed Medical Assistance Days


Review whether Medicare administrative contractors properly settled cost reporting for Medicare disproportionate share hospital payments.

Inpatient Psychiatric Facility Outlier Payments


Review if facilities complied with documentation, coverage, and coding requirements for stays that resulted in outlier payments.

Drug Waste of Single-Use Vials


Review the amount of waste from single-use vial drugs with the highest amount paid for waste as identified by the JW modifier to identify opportunities to significantly reduce waste.

Intensity-Modulated Radiation Therapy


Review to determine whether services were correctly billed (planning versus delivery) and reimbursed.

Outpatient Outlier Payments For Short-Stay Claims

Study to determine the potential Medicare program savings if hospital outpatient stays were ineligible for an outlier payment.

Comparison of Provider-Based and Freestanding Clinics

Study to evaluate the potential impact on the Medicare program as well as beneficiaries of hospitals claiming provider-based status for such facilities.

Hospital Use of Outpatient and Inpatient Stays Under Medicare’s Two-Midnight Rule

Study to determine how hospitals’ use of outpatient and inpatient stays changed under Medicare’s two-midnight rule by comparing claims for hospital stays in the year prior to and the year following the effective date of the rule (October 1, 2013).

Payment Credits for Replaced Medical Devices That Were Implanted

Review accuracy of Medicare payments for replaced medical devices because of defects, recalls, mechanical complications, etc.

Medicare Payments for Overlapping Part A Inpatient Claims and Part B Outpatient Claims

Review certain types of inpatient hospitals to determine whether outpatient claims billed to Medicare Part B for services provided during inpatient stays were made in accordance with Federal requirements.

Selected Inpatient and Outpatient Billing Requirements

Review Medicare payments to acute care hospitals to determine compliance with selected billing requirements that may be at risk for overpayments.

Medicare Education Payments

Review to identify duplicate Graduate Medical Education payments and improperly calculated Indirect Medical Education payments.

Cardiac Catheterization and Endomyocardial Biopsies

Review to identify improper payments to hospitals for outpatient right heart catheterizations and endomyocardial biopsies performed during the same encounter.

Inpatient Rehabilitation Facility Payment Requirements


Review whether claims were billed in compliance with Medicare documentation and coverage requirements.

Payments for Kwashiorkor

Review payments for claims that include a diagnosis of Kwashiorkor to determine whether the diagnosis is adequately supported by the medical record documentation.





Transitional Care Management


Review whether payments for transitional care management services were made in accordance with Medicare requirements.

Chronic Care Management


Review whether payments for chronic care management services were made in accordance with Medicare requirements.


Review whether payments for anesthesia services were made in conjunction with a related Medicare service and whether anesthesia services reported with the modifier AA, indicating the service was personally performed by the anesthesiologist, were reported and paid correctly.

Physician Home Visits

Review to determine whether Medicare payments for E/M home visits were reasonable and necessary in lieu of an office or outpatient visit.

Prolonged E/M Services

Review to determine whether Medicare payments for prolonged E/M services were reasonable and necessary.

Chiropractic Services

Review to determine if payments were made for non-covered conditions and services.

Physical Therapy

Review physical therapy providers with high utilization rates for outpatient physical therapy services to determine whether services were provided and documented in compliance with Medicare reimbursement regulations.

Sleep Testing

Review sleep testing providers with high utilization rates for sleep testing services to determine whether services were provided and documented in compliance with Medicare reimbursement regulations.

We recommend Medicare providers review the Work Plan Update for FY 2017 in its entirety. We also recommend providers conduct proactive audits of the applicable areas identified in the update.

HBE Advisors staff includes certified coders, physicians, consultants certified in healthcare compliance, and statisticians that are available to provide expert assistance with your Medicare and Medicaid compliance auditing and monitoring functions.

To read the complete FY 2017 Work Plan Update, please click on the following link: https://oig.hhs.gov/reports-and-publications/workplan/index.asp.

DISCLAIMER:  This post contains only summary information and highlights; it should be read in conjunction with the full article or document provided as a link.  Any advice or recommendations given are general and specific questions should be directed to professional counsel.

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