A biweekly publication from the Healthcare Group at Feeley & Driscoll, P.C.
Please visit us at our website: www.fdcpa.com/healthcare.htm. This OIG Update is also accessible from the F&D website, by visiting www. fdcpa.com/oig.updates.htm.
In This Issue
- Iowa Medicaid Payments for Skilled Professional Medical Personnel
- Audit of Anthem Insurance Company's Unfunded Pension Costs for 1991 Through 2002
- Review of Pension Costs Claimed for Medicare Reimbursement by Blue Cross Blue Shield of Utah for Fiscal Years 1987 Through 1997
- Audit of Blue Cross Blue Shield of Utah 's Unfunded Pension Costs for 1986 Through 1997
- Medical Review of Green Cross's Partial Hospitalization Services for the Period August 1, 2000 , Through December 31, 2002
- OIG Today posts Advisory Opinion 06-04 on a patient assistance program to the website.
1. Iowa Medicaid Payments for Skilled Professional Medical Personnel (A-07-05-03062)
The objective of this review was to determine whether inpatient rehabilitation facilities (IRFs) under the administrative responsibility of United Government Services, LLC (UGS) billed fiscal year-end inpatient rehabilitation claims in accordance with Medicare requirements during the transition to the prospective payment system in 2002. Thirty-five IRFs did not bill 340 fiscal year-end claims in accordance with Medicare requirements. As a result, Medicare made net overpayments of $516,303. Some IRFs did not have adequate controls to ensure that claims submitted at fiscal year-end were billed in accordance with Medicare requirements, and two IRFs stated that they had received inaccurate information from UGS.
The OIG recommended that UGS make the appropriate adjustments to paid claims that resulted in net overpayments of $516,303 to the thirty-four IRFs and continue education efforts for IRF and UGS personnel. UGS agreed with their recommendations.
To read the report visit: http://www.oig.hhs.gov/oas/reports/region7/70503062.pdf
2. Audit of Anthem Insurance Company's Unfunded Pension Costs for 1991 Through 2002 (A-07-06-00205)
The OIG’s objectives were to: (1) determine if the accumulated unfunded pension costs identified in the OIG’s prior reviews were accounted for properly; (2) determine if pension costs for the audit period (1991-2002) were funded in accordance with the Federal Acquisition Regulations (FAR) and the Cost Accounting Standards (CAS); and (3) identify and properly account for any additional accumulated unfunded pension costs, including the identification of the unallowable and reassignable portions of the accumulated unfunded pension costs. The OIG found that Anthem properly accounted for previously identified unfunded pension costs in accordance with Federal regulations. For the current audit period, Anthem funded its pension costs in accordance with the FAR and CAS. However, as a result of the merger with Blue Cross Blue Shield of Connecticut, Anthem has unallowable unfunded pension costs for the Other segment. The accumulated unallowable pension cost is $6,052,895 as of January 1, 2003 .
The OIG recommended that Anthem: (1) identify $6,052,895 of accumulated unallowable pension costs as of January 1, 2003, and (2) identify and properly track unallowable unfunded pension costs in subsequent years. Anthem agreed with the OIG’s finding and recommendations and stated that it had already implemented policies and procedures to ensure that unallowable unfunded pension costs were properly tracked in the future.
To read the report visit: http://www.oig.hhs.gov/oas/reports/region7/70600205.pdf
3. Review of Pension Costs Claimed for Medicare Reimbursement by Blue Cross Blue Shield of Utah for Fiscal Years 1987 Through 1997 (A-07-06-00199)
The objective of the OIG’s review was to determine the allowability of pension costs claimed for Medicare reimbursement for fiscal years (FY) 1987 through 1997. The OIG found that Utah did not claim all pension costs that were allowable for Medicare reimbursement for FYs 1987 through 1997 because it did not claim pension costs in accordance with its Medicare contracts. Therefore, Utah underclaimed $756,509 of allowable pension costs. The OIG recommended that Utah revise its Final Administrative Cost Proposals (FACP) to claim allowable CAS pension costs of $756,509 for FYs 1987 through 1997. Utah concurred with the OIG’s recommendation.
To read the report visit: http://www.oig.hhs.gov/oas/reports/region7/70600199.pdf
4. Audit of Blue Cross Blue Shield of Utah 's Unfunded Pension Costs for 1986 Through 1997 (A-07-06-00198)
The OIG’s objectives were to: (1) determine if pension costs for plan years 1986 through 1997 were funded in accordance with the Federal Acquisition Regulations and the Cost Accounting Standards and (2) identify and properly account for any accumulated unfunded pension costs, including unallowable and reassignable portions. The OIG found that Utah did not properly fund the pension costs allocable to the Medicare contracts for plan years 1993 and 1995. In addition, Utah did not identify or properly account for accumulated unfunded pension costs. As a result, Utah understated the January 1, 1998, accumulated unallowable pension costs by $202,066 ($174,774 for the Other segment plus $27,292 for the Medicare segment). The OIG recommended that Utah identify accumulated unallowable pension costs of $202,066 ($174,774 for the Other segment plus $27,292 for the Medicare segment) as of January 1, 1998. Utah concurred with the OIG’s recommendation.
To read the report visit: http://www.oig.hhs.gov/oas/reports/region7/70600198.pdf
5. Medical Review of Green Cross's Partial Hospitalization Services for the Period August 1, 2000, Through December 31, 2002 (A-04-04-02003)
The OIG’s objective was to determine whether the claims that Green Cross, Inc. submitted for partial hospitalization program (PHP) services met Medicare reimbursement requirements. Green Cross submitted claims for PHP services that did not meet Medicare reimbursement requirements. Medical reviewers determined that 95 of the 100 sampled PHP claims did not meet Medicare reimbursement requirements relating to initial certification/evaluation, recertification, and/or beneficiary eligibility. The OIG recommended that CMS determine the allowability of the claims that resulted in the OIG’s $4,762,036 statistical estimate of unallowable payments. In its comments on the OIG’s draft report, Green Cross strongly disagreed with the findings and took issue with many aspects of the review, including the audit process and the medical determinations.
To read the report visit: http://www.oig.hhs.gov/oas/reports/region4/40402003.pdf
6. OIG Today posts Advisory Opinion 06-04 on a patient assistance program to the website.
From the Inspector General:
"This new advisory opinion emphasizes yet again that lawful avenues exist for pharmaceutical manufacturers and others to help financially-needy patients, including beneficiaries enrolled in Medicare Part D," said Daniel R. Levinson, Inspector General of the Department of Health & Human Services. "As I have said in the past, and as the OIG’s previous guidance has made clear, OIG recognizes the importance of helping financially-needy Medicare patients obtain necessary outpatient prescription drugs."
To access the Advisory Opinion document, 06-04 (concerning a nonprofit, tax-exempt, charitable corporation's proposal to provide financially needy Medicare beneficiaries with assistance with premiums and cost-sharing obligations under Medicare Part B, Medicare Part D, Medigap [as hereinafter defined], and Medicare Advantage) go here: http://www.oig.hhs.gov/fraud/docs/advisoryopinions/2006/AdvOpn06-04A.pdf.
For the index of recent OIG Advisory Opinions, follow this link: http://oig.hhs.gov/fraud/advisoryopinions/opinions.html
To see "Frequently Asked Questions" (FAQs) on the OIG Advisory Opinion process, go here: http://oig.hhs.gov/fraud/advisoryopinions/aofaq.html
If you have any questions or would like to discuss any of these issues with one of Feeley & Driscoll’s healthcare specialists, please contact us at (617) 742-7788 or via e-mail at info@fdcpa.com.
Feeley & Driscoll, P.C. is one of the largest regionally based providers of accounting and business advisory services to the healthcare market in New England. Our experience in the healthcare and human services field covers an extensive and diverse range of clients and engagements. Our practice reflects the three major forces in the healthcare industry: hospitals, physicians, and extended care providers. The services that we offer our clients cover a broad spectrum from traditional audit and tax services to reimbursement and financial planning services to marketing/strategic planning and regulatory compliance. Our goal is to provide each of their clients with superior, quality service. To this end, we have assembled a team of business advisors with a year-round commitment to the healthcare industry and its dynamic environment. Each of the professionals on our healthcare team has a thorough and complete working knowledge of accounting, auditing, reimbursement, compliance, and related issues impacting the healthcare industry. |
