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OIG Work Plan Update

OIG Work Plan Update October 23, 2019

The OIG monthly Work Plan was released just last week with several notable additions.

  • Speech Therapy Services – The focus will be outpatient therapy claims billed with the KX modifier  and will determine whether the claims met Federal requirements for reasonableness and medical necessity for beneficiary services which have exceeded the annual therapy cap.  Additionally, the OIG will look at payment trends for speech therapy services billed with the KX modifier to identify services that may be unallowable.
  • Urine Drug Testing – The OIG will review urine drug testing services provided to beneficiaries with substance use disorder (SUD) related diagnoses to determine compliance with Medicare requirements. 
  • Positive airway pressure (PAP) replacement supplies – Reviews of suppliers claims will be conducted to ensure compliance with Medicare requirements for replacement supplies for PAP devices.

We recommend you review all active Work Plan items to identify known risk areas that may affect your organization.  Identified risk areas applicable to your organization should be incorporated into your auditing and monitoring plan to evaluate your compliance with the regulations and guidelines.  HBE’s team of experts is available to assist you with risk assessments, routine auditing and monitoring, policy and procedure development as well as customized education and training for your clinical and administrative staff.

The OIG Work Plan can be found at:

If you are interested in learning more about our audit or compliance services, please contact us.

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