OIG Work Plan 2016: 3 Things Healthcare Organizations Can Expect
In case you may have missed it, the Office of Inspector General (OIG) published its latest Work Plan for fiscal year 2016 last week. Each year, healthcare organizations should review their compliance programs to ensure they address the regulatory agency’s latest areas of focus. During this year’s HCCA Healthcare Enforcement Institute, it became very clear that healthcare organizations are facing a regulatory environment with increased enforcement, as regulatory agencies have more access to data that has helped them become more efficient in their efforts.
While you should certainly review the document in its entirety to see which sections affect your organization specifically, here’s a quick overview of some of the sections that caught my attention.
Update Your Exclusion Screening Program to Keep Up with Increased Exclusions
In fiscal year 2015, the OIG reported exclusions of 4,112 individuals and entities from participation in federal healthcare programs. With the OIG’s exclusions on the rise, it’s important to follow exclusion screening best practices to ensure your organization is not engaging excluded individuals or entities. In the agency’s 2013 Special Advisory Bulletin on exclusion screening, the OIG set monthly exclusion screening as the new standard or best practice for healthcare organizations. Since the agency updates its List of Excluded Individuals and Entities (LEIE) on a monthly basis, screening the OIG’s exclusion list each month will minimize the level of risk for having excluded individuals or entities on staff. Healthcare organizations are also highly recommended to check the state medicaid exclusion lists, since the Affordable Care Act (ACA) providers excluded in one state Medicaid program should be excluded in all.
Oversight of States’ Background Screening of Physicians
Beginning on August 1, 2015, providers considered at “high risk” for defrauding state Medicaid programs are required by CMS to undergo a criminal background check that includes fingerprinting. According to the OIG’s updated Work Plan, the agency plans to review whether States are conducting enhanced screenings that assess risk for fraud, waste, and abuse for moderate- and high-risk enrolling and revalidating Medicaid providers and suppliers. They will also determine the extent to which States have screened moderate- and high-risk providers and suppliers using these risk-based screenings.
ICD-10 Implementation is No Longer Optional
We all knew this was coming, and although it was delayed for a year, the ICD-10 deadline is behind us. Starting on October 1, 2015, Medicare claims with a date of service on or after October 1, 2015, are required to have a valid ICD-10 code. The ICD-10 system includes about 70,000 diagnosis and replaces the use of ICD-9 in Medicare, which included only about 15,000 codes. The good news for healthcare organizations is that CMS has advised providers it will allow for some flexibility during the first 12 months of implementation. For example, Medicare review contractors will not deny claims billed under the Part B physician fee schedule based solely on the specificity of the ICD-10 diagnosis code as long as the physician/practitioner used a code from the correct “family” of codes. Nevertheless, it’s important to ensure your organization’s implementation of ICD-10 is effective, efficient and compliant. In order to ensure accurate use of the ICD-10 diagnostic codes, some healthcare organizations have hired medical scribes to assist physicians in the documentation.
What areas of the the OIG’s Work Plan 2016 will affect your organization’s compliance program? Let us know in the comments section below.