Yesterday, the OIG released their monthly Work Plan update.  There are a number of notable additions including:

• Payments for positive airway pressure devices (PAP)– The OIG will be auditing DME providers who provide and bill for PAP devices to determine whether the Medicare coverage and payment criteria are met. Specifically, they will be looking at whether an appropriate sleep study was performed prior to dispensing the PAP device.

• Payments to providers for services rendered to nursing home patients– The OIG will be conducting audits of Part B claims and payments for physicians and non-physician practitioners for services rendered to nursing home patients.  The OIG will specifically be looking for fraudulent, excessive and unnecessary services.

• Facet joint injections– The OIG has previously identified “significant billing errors” related to facet joint injections and will be conducting audits to determine whether coverage and payment criteria are met.

• DRG payment window– The OIG will be examining the number of admission-related outpatient services that were payable outside the 3-day DRG payment window.  The purpose of the study will be to identify potential savings to the Medicare program by expanding the DRG payment window to more days and including more ownership structures in the payment bundle, as well as, identifying alternate payment models.

We recommend you review all of the active Work Plan items to identify known risk areas within your organization and incorporate them into your own compliance audit program.  The HBE team is available to assist you with your risk assessment, audit and education efforts.

The complete Work Plan can be accessed at:  https://oig.hhs.gov/reports-and-publications/workplan/index.asp