Happy Halloween!  In addition to costumes and candy, October 31 saw the release of the 2015 Work Plan by the Office of Inspector General for Health and Human Services.  Always a lengthy document, the Work Plan can indicate areas that providers and suppliers want to monitor closely, as they are areas receiving attention from the government.  In addition to continuing many of the existing areas of focus, this year adds several new categories, including:

  • Hospital electronic health record system contingency plans required by HIPAA;
  • Review of hospital wage data used to calculate Medicare payments;
  • Adverse events in post-acute care in long-term-care hospitals (an area previously reviewed for inpatient rehab facilities);
  • Independent clinical laboratory billing requirements; and
  • Medicaid MCO payments for services after a beneficiary’s death or for ineligible beneficiaries.

The Work Plan also emphasizes the large recoveries made by the OIG in 2014, as well as the number of Medicare exclusions, criminal convictions, and civil recoveries for healthcare fraud in 2014, consistent with the Department of Justice’s recent emphasis on prosecuting companies and individuals for fraud as we reported previously.