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Delaware Health Law Blog


Yesterday the OIG issued its Work Plan describing the activities the OIG plans to initiate or continue with respect to HHS programs and operations in fiscal year 2013. The Plan identifies areas of government focus for each type of healthcare provider, as well as the OIG’s planned activities related to its oversight of Medicare Part A and B contractors, Medicare Part C and D programs, state Medicaid plans, and public health and human services agencies within the U.S. Department of Health and Human Services. With respect to particular healthcare providers, the Plan identifies 11 new initiatives related to hospitals, 3 related to nursing homes, 2 related to home health agencies, 8 related to medical equipment suppliers, and 8 related to all other providers and suppliers. The new hospital initiatives include a review of Medicare payments made to hospitals for beneficiary discharges that should have been coded as transfers, a review of Medicare payments made to hospitals for beneficiary discharges that were coded as discharges to a swing bed in another hospital, and an analysis of costs incurred by Medicare related to inpatient hospital claims for canceled surgical procedures. For nursing homes, two of the new initiatives relate to evaluating whether states are properly performing oversight functions mandated by federal regulations, specifically whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys, and the extent to which CMS and the States oversee the accuracy and completeness of Minimum Data Set (MDS) data submitted by nursing facilities. The OIG plans to determine the extent to which home health agencies are complying with the statutory requirement that physicians who certify beneficiaries as eligible for Medicare home health services have face-to-face encounters with the beneficiaries. The OIG will also review which home health agencies are complying with State requirements for conducting criminal background checks of applicants and employees. With respect to medical equipment and supplies, the OIG plans to audit payments for lower limb prosthetics, power mobility devices and blood glucose test strips and lancets. As to all other providers, the OIG’s new initiatives include reviews of Medicare Part B claims for personally performed anesthesia services to determine whether they were supported in accordance with Medicare requirements, an examination of questionable billing practices for ophthalmological services during 2011, and a review of questionable billing for electrodiagnostic testing, which is used in the diagnosis and treatment of nerve or muscle damage and includes the needle electromyogram and the nerve conduction test. These efforts described in these new initiatives, as well as the others identified in the OIG Work Plan, are in addition to the OIG’s ongoing audits and analyses of numerous other provider-specific issues, all of which are outlined in the Work Plan, which is available at The OIG is also planning a webcast on October 24, 2012, during which top OIG personnel will describe the OIG’s priorities for combating fraud, waste and abuse in federal health care programs for 2013. More information about the webcast is available at the above link.

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