On Tuesday, Oct. 2, the Office of the Inspector General (OIG) published their Work Plan for 2013. The OIG Work Plan describes activities the OIG will initiate or continue throughout the year. Through its activities, the OIG seeks to fight waste, fraud and abuse in the US Department of Health and Human Services (HHS) programs such as Medicare. Three sleep-specific issues were identified for the 2013 Work Plan. The Work Plan indicates that the OIG intends to publish reports on all three issues this year.
Continuous Positive Airway Pressure Supplies: The OIG will compare Medicare CPAP supply replacement schedules to the replacement schedules of other Federal programs such as Medicaid and VA. The work plan notes that there are no national coverage determinations for replacement of CPAP supplies – replacement schedules are designated by the Medicare Administrative Contractors. By comparing Medicare replacement to that of other Federal programs, the OIG seeks to identify potential areas of wasteful spending and consider the adoption of new replacement schedules.
Sleep Testing – Appropriateness of Medicare Payments for Polysomnography: The OIG will review claims for sleep studies provided in 2009 and 2010. The impetus for this review is the significant increase in billing of polysomnography from 2001-2009 (from $62 million to $235 million). Specifically, the OIG will be reviewing what it considers to be “questionable billing patterns” for sleep study services.
Sleep Disorder Clinics – High Utilization of Sleep Testing Procedures: The OIG will be reviewing 2010 Medicare payments for in-center polysomnography (code 95810) and in-center PAP titration (code 95811) to determine whether or not the tests were performed according to Medicare’s requirements. Tests performed in free standing facilities, hospitals and IDTFs will be reviewed for medical necessity. The OIG is looking to determine whether tests performed were duplicative and/or not reasonable and necessary.