The American Hospital Association (AHA) and its consitituents continue to vent to the U.S. Department of Health and Human Services Office of the Inspector General about the use of extrapolation techniques to determine how much hospitals have been overpaid by the Medicare program.
The AHA sent a letter last month to the Office of Inspector General, asking that the practice--which uses a small sample of claims to determine an entire universe of overpayments to hospitals--be stopped, according to AHA News Now.
The Nov. 20 letter, written by AHA Senior Vice President and General Counsel Melinda Hatton, concluded the use of extrapolation for hospital compliance audits is deeply flawed.
Among the issues raised by the AHA, the Centers for Medicare & Medicare Services policy on short inpatent hospital stays "has been woefully inadequate" and CMS does not offset the amount it believes a hospital is being overpaid by Medicare Part B payments for outpatient care that it would be entitled to receive.
AHA also claims CMS does not allow hospitals to challenge the extrapolation methodology through the appeals process for the entire amount but must litigate each rejected claim. In this last instance, Hatton noted that at least two hospital operators--Orlando Health and Hackensack University Health--are attempting to appeal the entire overpayment amount and methodology for arriving at the figure, despite there not being a clear process for doing so.
"Even setting aside the fact that the OIG's singular focus on short inpatient stays is unnecessary and duplicative of the Recovery Audit Contractor activities and other audits, the OIG's almost exclusive reliance on short inpatient stays to generate multi-million-dollar estimated overpayments also unfairly prejudices hospitals," Hatton wrote.
AHA has been hammering away at this issue for months, sending at least two letters to the OIG earlier this year asking it stop using extrapolations to determine overpayments.
Hatton and the AHA also accused CMS of "inventing" the need for a physician order for short hospital stays in order to justify receiving payment under Medicare Part B if it has been rejected under Part A. And it asked the agency to not use extrapolation methodologies for inpatients admitted for a surgical procedure that it is then canceled.