OIG 2010 work plan includes RAC-like focus areas

The 2010 Work Plan released by the HHS Office of the Inspector General is certainly a dry document, but healthcare providers should be careful not to miss some key provisions, according to an industry compliance consultant.

Some key examples identified by the consultant--Bret S. Bissey, MBA, FACHE, CHC--include plans to review Medicare payments for hospital observation services during outpatient visits under Part B coverage. The OIG plans to determine whether these services, a spark point for Recovery Audit Contractor audits, are being delivered according to CMS guidelines. It also plans to examine the current version of the DRG system--which includes 745 items--to see which DRGs are susceptible to upcoding.

Meanwhile, the OIG plans to take on another task that should be of interest those who feel the RACs have gone too far. The OIG plans to review CMS's oversight of RACs during the three-year demonstration program, looking at how often and when the RACs reported on potential fraud. (Admittedly, the OIG rein the RACs in, but the office could just as easily conclude that the RACs should hit harder.)

"If your colleagues still don't understand the threat of the RACs, consider utilizing these aspects of the 2010 OIG Work Plan in your compliance education efforts," Bissey suggests.

To review this analysis:
- read this RAC Monitor piece

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Hospital Impact - 'Take the RAC program very seriously,' Florida hospitals warn 
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