2014 OIG Work Plan Summary – Part 3: Nursing Homes

This post is part of a series of articles summarizing various elements of the 2014 Work Plan of the Office of Inspector General of the Department of Health and Human Services (OIG).  The prior post in this series focused on OIG initiatives relating to Physician Reviews.  This post outlines several OIG initiatives for 2014 relating to nursing homes.

Medicare Part A Billing by Skilled Nursing Facilities

An OIG study of skilled nursing home billings under Medicare Part A found that nearly one-quarter of all 2009 skilled nursing home claims were incorrect, resulting in approximately $1.5 billion of inappropriate Medicare payments.  The OIG has also noted that skilled nursing facilities are increasingly billing for the highest level of therapy, even though the skilled nursing needs of their residents has not changed.  In response to these findings, CMS has already implemented revisions to skilled nursing home billing requirements under Medicare Part A.  The OIG will be reporting on skilled nursing facility billing practices in particular years, including variations in billing practices among skilled nursing facilities.

Medicare Part B Billing by Nursing Homes

In response to explicit instructions from Congress to monitor Medicare Part B billing practices by nursing homes for abuse, the OIG is studying billing practices of nursing homes and Medicare providers of Part B services across a number of broad categories of services.

Verification of Deficiency Correction

The OIG plans to continue to monitor state survey agencies to make sure that those agencies are properly verifying that deficiencies identified during the nursing home recertification survey process have been corrected.   The OIG previously identified at least one state survey agency that failed to comply with the Federal requirement that each state survey agency verify that deficiencies identified during the recertification process have been corrected.

National Background Checks for Long-Term-Care Employees

The OIG is reviewing the procedures implemented by a number of states as part of a program to conduct background checks on employees of long-term-care facilities and providers.  One goal of the review is to identify whether the background checks have led to any unintended consequences.

Hospitalizations of Nursing Home Residents

In FY2011, nearly 25% of Medicare beneficiaries were hospitalized.  Given the high cost of hospitalizing nursing home residents in particular, and the possibility that the high rate of nursing home resident hospitalizations may indicate a quality of care problem at the nursing home level, the OIG will study hospitalizations of nursing home residents for conditions that are typically preventable or manageable within the nursing home setting.

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About Jeff Swaim

Jeff is a partner and a former chair of the firm's Business Group. He has extensive experience practicing in the areas of mergers and acquisitions, equity financing, securities regulation, contract drafting and negotiation, business formation, corporate governance, and general corporate and business matters. He has worked with clients in a wide range of industries, including manufacturing, plastics, medical devices, health services, life sciences, publishing, telecommunications, internet services, software, high-technology, financial services, and the media. Jeff's clients range in size from small start-up ventures to large multi-national public companies.
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