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:
1. OIG posts a press release on a research compliance program guidance initiative.
2. OIG posts updated exclusion and reinstatement files, to the website.
3. Medicaid Outlier Payments at Inpatient Hospitals in Texas (A-06-04-00051)
4. Review of Controls to Report Wage Data at Sarasota Memorial Hospital for the Period of October 1, 2002, Through September 30, 2003 (A-04-05-02001)
5. Excessive Payments for Outpatient Services Processed by Mutual of Omaha (A-01-05-00514)
6. Review of Undistributable Child Support Collections in Wisconsin From October 1, 1998, Through September 30, 2005 (A-05-06-00018)
1. OIG posts a press release on a research compliance program guidance initiative.
NSTC Launches Government-wide Initiative Based on OIG Draft Guidance for HHS Research Grants
Inspector General Daniel R. Levinson of the Department of Health and Human Services (HHS) Office of Inspector General (OIG) announced today that OIG has concurred with the Committee on Science (COS), National Science and Technology Council (NSTC) offer to expand upon OIG's initial efforts to provide voluntary compliance guidance to recipients of Federal research funding. The Committee on Science met today and concurred that their Research Business Models Subcommittee will establish an inter-agency initiative to develop voluntary compliance guidelines for recipients of Federal research funding from all agencies across the Federal Government. OIG's "Draft Compliance Program Guidance for Recipients of PHS [Public Health Service] Research Awards" (Draft Guidance) was published for public comment in the Federal Register on November 28, 2005.
To access the full release: http://www.oig.hhs.gov/publications/docs/press/2006/ResearchCPG-finalrelease06072006.pdf
2. OIG posts updated exclusion and reinstatement files, to the website.
This is the full "Updated LEIE" database file reflecting all OIG exclusion and reinstatement actions up to, and including, those taken in May of 2006. This new, "Updated LEIE" (List of Excluded Individuals and Entities) is a complete database file containing all exclusions currently in effect. Individuals and entities that have been reinstated to the federal health care programs are not included in this file.
This is meant to REPLACE the "Updated LEIE" file made available for download last month. The new file is complete and should NOT be used in conjunction with the monthly exclusion and reinstatement supplements. You can download the full "Updated LEIE" from here: http://oig.hhs.gov/fraud/exclusions/database.html#1
If, though, you are one of the few continuing to use the "Standard LEIE" database file you will need to add the exclusion as well as the reinstatement actions taken in May. These monthly supplement files, which have other uses as well, are both available for download from here: http://oig.hhs.gov/fraud/exclusions/database.html#2
All of these downloadable files are zipped, self-extracting .dbf files, meaning that they will not open automatically when you click on the links. After you have downloaded the files to your computer (or "disk" in technospeak) and inflated them, the files must be opened into either a spreadsheet program such as Excel, or a database program such as Access.
Basic download instructions are provided on the OIG website here: http://oig.hhs.gov/fraud/exclusions/instructions.html. If you would like to have some more comprehensive download instructions emailed to you, just let OIG know.
Finally, it should be added, the full LEIE database -- complete with these updates -- is included in the OIG "Online Searchable Database" which is very user-friendly and may be accessed here: http://exclusions.oig.hhs.gov/search.html
3. Medicaid Outlier Payments at Inpatient Hospitals in Texas (A-06-04-00051)
OIG’s objective was to determine whether the Texas Health and Human Services Commission (the State agency) limited cost outlier payments to exceptionally high-cost cases. The State agency did not limit cost outlier payments to exceptionally high-cost cases. Specifically, the State agency (1) did not use current cost-to-charge ratios, (2) used no covered charges in calculating the outlier payments, and (3) did not have sufficient policies and procedures in place to monitor cost outlier payments. OIG recommended that the State agency (1) revise its method of computing cost outlier payments and (2) develop policies and procedures to more closely monitor outlier payments. Texas disagreed with their recommendation to revise its method of computing cost outlier payments but agreed to review its processes and update its formal policies.
To access the full article: http://www.oig.hhs.gov/oas/reports/region6/60400051.pdf
4. Review of Controls to Report Wage Data at Sarasota Memorial Hospital for the Period of October 1, 2002, Through September 30, 2003 (A-04-05-02001)
The objective of OIG’s review was to determine whether Sarasota Memorial Hospital (the hospital) complied with Medicare requirements for reporting wage data in its fiscal year (FY) 2003 Medicare cost report. The hospital did not fully comply with Medicare requirements for reporting wage data in its FY 2003 Medicare cost report. The hospital understated its wage data by $2,926,445 and 175,695 hours.
OIG recommended that the hospital (1) submit a revised FY 2003 Medicare cost report to the fiscal intermediary to correct the understatements in the wage data totaling $2,926,445 and 175,695 hours and (2) implement review and reconciliation procedures to ensure that the wage data reported on future Medicare cost reports are accurate, supportable, and in compliance with Medicare requirements. The hospital agreed with the findings and recommendations.
To access the full article: http://www.oig.hhs.gov/oas/reports/region4/40502001.pdf
5. Excessive Payments for Outpatient Services Processed by Mutual of Omaha (A-01-05-00514)
OIG’s objective was to determine whether high-dollar Medicare payments that Mutual of Omaha made to providers for outpatient services were appropriate. Some of the high-dollar Medicare outpatient payments were not appropriate. During calendar year 2003, Mutual of Omaha made 54 payments of $50,000 or more each for outpatient services. At the start of OIG’s fieldwork in April 2005: (a) 9 of the payments were correct; (b) 17 of the payments were incorrect, and the providers had refunded $5,466,816 in overpayments; and, (c) 28 of the payments were incorrect, and the providers had not refunded $2,808,384 in associated overpayments. Contrary to Federal guidance, the providers in all 45 (17 plus 28) instances inappropriately overstated the units of service.
OIG recommended that Mutual of Omaha: (1) inform them of the status of the recovery of the $2,808,384 in overpayments that their audit identified, (2) identify and recover additional overpayments made on high-dollar outpatient claims paid after calendar year 2003, and (3) use the results of this audit in its provider education activities. Mutual of Omaha agreed with OIG’s recommendations.
To access the full article: http://www.oig.hhs.gov/oas/reports/region1/10500514.pdf
6. Review of Undistributable Child Support Collections in Wisconsin From October 1, 1998 , Through September 30, 2005 (A-05-06-00018)
OIG’s objectives were to determine whether the Wisconsin Department of Workforce Development (State agency) appropriately reported program income for undistributable child support collections and interest earned on program funds. For the quarters ended December 1998 through September 2005, the State agency did not recognize and report program income of $162,701 ($107,383 Federal share) for undistributable collections. The State agency properly reported interest earned on program funds as program income. OIG recommended that the State agency make the appropriate program income adjustments for undistributable collections, require the Milwaukee agency to transfer unclaimed collections to the treasurer's office and implement adequate policies and procedures to ensure future undistributable collections are recognized as program income on Federal financial reports. The State agency agreed with the audit recommendations.
To access the full article: http://www.oig.hhs.gov/oas/reports/region5/50600018.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.htm
For more information regarding the OIG's Exclusion Program, please follow this link: http://oig.hhs.gov/fraud/exclusions.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. |
