Saturday, February 1, 2014

OIG Work Plan for SNFs 2014

Medicare Part A billing by skilled nursing facilities (new) 
Policies and Practices. We will describe SNF billing practices in selected years and will describe variation in billing among SNFs in those years. Context—Prior OIG work found that SNFs increasingly billed for the highest level of therapy even though beneficiary characteristics remained largely unchanged. OIG also found that SNFs billed one-quarter of all 2009 claims in error, resulting in $1.5 billion in inappropriate Medicare payments. CMS has made substantial changes to how SNFs bill for services for Medicare Part A stays. (OEI; 02-13-00610; 00-00-0000; various reviews; expected issue date: FY 2014; work in progress) 
 Questionable billing patterns for Part B services during nursing home stays 
Billing and Payments. We will identify questionable billing patterns associated with nursing homes and Medicare providers for Part B services provided to nursing home residents during stays not paid under Part A (for example, stays during which benefits are exhausted or the 3-day prior-inpatient-stay requirement is not met). A series of studies will examine several broad categories of services, such as foot care. Context—Congress explicitly directed OIG to monitor Part B billing for abuse during non-Part A stays. (Medicare, Medicaid, and SCHIP Benefits Improvement and Protection Act of 2000 (BIPA), § 313.) (OEI; 06-14-00160; various reviews; expected issue date: FY 2014; work in progress) 
 State agency verification of deficiency corrections 
Quality of Care and Safety—We will determine whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys. Context—A prior OIG review found that one State survey agency did not always verify that nursing homes corrected deficiencies identified during surveys in accordance with Federal requirements. Federal regulations require nursing homes to submit correction plans to the State survey agency or CMS for deficiencies identified during surveys. (42 CFR § 488.402(d).) CMS requires State survey agencies to verify the correction of identified deficiencies through onsite reviews or by obtaining other evidence of correction. (State Operations Manual, Pub. No. 100-07, § 7300.3.) (OAS; W-00-13-35701; W-00-14-35101; various reviews; expected issue date: FY 2014; work in progress) 
 Program for national background checks for long-term-care employees 
Quality of Care and Safety. We will review the procedures implemented by participating States for long-term-care facilities or providers to conduct background checks on prospective employees and providers who would have direct access to patients and determine the costs of conducting background checks. We will determine the outcomes of the States' programs and determine whether the programs led to any unintended consequences. Contex—This mandated work is ongoing and will be issued at the program's conclusion as required. (Affordable Care Act, § 6401.) (OEI; 07-10-00420; expected issue date: FY 2017; work in progress; Affordable Care Act) HHS OIG Work Plan | FY 2014 Medicare Part A and Part B Page 9 
 Hospitalizations of nursing home residents for manageable and preventable conditions 

Quality of Care and Safety—We will determine the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting. Context—A 2013 OIG review found that 25 percent of Medicare beneficiaries were hospitalized for any reason in FY 2011. Hospitalizations of nursing home residents are costly to Medicare and may indicate quality-of-care problems in the nursing homes. (OEI; 06-11-00041; expected issue date: FY 2014; work in progress) 

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