Late last week, the HHS OIG made available its semi-annual report to Congress summarizing OIG activities occurring from October 1, 2017 to March 31, 2018. As one might expect, OIG continues to commit resources to enforcement-related activities and to improve its data analytics capabilities. A few of the “headlines” from an enforcement perspective include:
- Criminal actions brought against 424 individuals and entities allegedly engaged in crimes against HHS programs;
- Exclusion from participation in Federal health care programs of 1,588 individuals and entities;
- Civil actions brought against 349 individual and entities; and
- Anticipated recoveries exceeding $1.4 billion from investigations
Many familiar themes and issues were examined by the OIG Office of Audit Services during the six-month period in question. Findings from select audits were that:
- On an extrapolated basis, one MAC was found to have paid as much as $42.3 million in improper payments to 73 providers for hyperbaric oxygen therapy services which did not comply with all requirements.
- An error rate of 100% was observed within a sample of 296 claims paid to 210 hospitals for the handling of manufacturer credits for recalled and failed cardiac medical devices.
- An extrapolation from a small sample of audited outpatient physical therapy claims suggested that $367 million in improper Medicare payments were made during the six-month period for services and associated medical records which did not comply with medical necessity, coding or documentation requirements.
- All but one of 2,145 inpatient claims for a diagnosis code 260 for Kwashiorkor were found to have been inaccurate.
- A total of $66.3 million was calculated to have been erroneously paid for specimen validity tests billed simultaneously with certain urine drug screens.
If your organization provides any of these services to Medicare beneficiaries, it is an opportune time to look at your adherence to applicable requirements for clinical documentation, medical necessity and billing within these areas.
A link to the detailed report is available here. https://oig.hhs.gov/reports-and-publications/semiannual/index.asp
By Sharon Parsley, Director of Content Development