On Oct 5 the Department of Health & Human Services (HHS) Office of Inspector General (OIG) announced the publication of the Fiscal Year 2012 HHS OIG Work Plan. The work plan, which can be downloaded for review in its entirety on the OIG website, outlines the items to be addressed by the OIG in the next fiscal year. The 2011 OIG Work Plan highlighted a number of sleep-related projects for the OIG and sleep continues to be an important topic in the 2012 Work Plan.
Issues Impacting Sleep Services in the 2012 OIG Work Plan
- Frequency of Replacement of Supplies for Durable Medical Equipment (p. I-14) – The plan indicates that “preliminary OIG work showed that suppliers automatically shipped continuous positive airway pressure system and respiratory-assist device supplies when no physician order for refills was in effect.”
- Sleep Disorders Clinics: Medicare Payments for Sleep Testing (p. I-21) – The plan describes a preliminary OIG review which “identified improper payments when certain modifier codes are not reported with sleep test procedures.” The plan indicates that the OIG will continue to examine these services.
- Sleep Testing: Appropriateness of Medicare Payments for Polysomnography (p. I-22) – The plan highlights the increase in payments for sleep studies (from $62 million in 2001 to $235 million in 2009).
Other Issues to Note in the 2012 OIG Work Plan
- Physician and Suppliers: Compliance with Assignment Rules (p. I-17) – The plan indicates a review of provider compliance with assignment rules to “determine to what extent beneficiaries are inappropriately billed in excess of amounts allowed by Medicare.”
- Physicians: Place-of-Service Errors (p. I-18) – The plan highlights that place of service will be reviewed for services performed in ambulatory surgical centers and hospital outpatient departments.
- Incident-to Services (p. I-18) – This issue is new to the 2012 work plan. The plan indicates that incident-to services will be reviewed “to determine whether payment for such services had a higher error rate than that for non-incident-to services.”
- Physicians: Impact of Opting Out of Medicare (p. I-18) – This issue is new to the 2012 work plan. The plan indicates that the OIG will review the frequency of physicians opting out of Medicare and whether physicians are opting out of Medicare more frequently in specific areas of the country.
- Evaluation and Management Services: Trends in Coding of Claims (p. I-19) – The plan indicates that E/M services from 2000-2009 will be reviewed to identify trends. Claims from 2009 will be reviewed particularly to “identify providers that exhibited questionable billing.”
Other Important Sections of the 2012 HHS OIG Work Plan
- The Introductory Message From the Office of the Inspector General(p. i) provides helpful information about the goals and mission of the OIG. Contact information is also provided.
- The Other Program-Related Reviews section of the plan (p. I-28) describes reviews of CMS programs that the OIG is currently performing or will perform in the future.
- Part IV of the plan, title Legal and Investigative Activities Related to Medicare and Medicaid (p. IV-1), provides helpful descriptions and links to additional information about OIG legal and investigative activities.
Coding Corner articles are archived on the Coding section of the AASM website for future reference.