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. Review of Hospital Wage Data Used To Calculate Inpatient Prospective Payment System Wage Indexes (A-01-05-00504)
2. Audit of Air Ambulance Claims Paid to Covenant Health System During Calendar Year 2002 (A-06-06-00046)
3. Review of the Management of Unobligated Funds Provided by Title I of the Ryan White Comprehensive AIDS Resources Emergency Act (A-02-03-02006)
4. Audit of Lebanon Repatriation Program Funds (A-01-07-02501)
5. Audit of New Mexico’s Title IV-E Contracted University Training Costs for the 2-Year Period Ended September 30, 2002 (A-06-06-00045)
6. Testimony Given by Inspector General Daniel R. Levinson
7. Tenet Choices 65's Adjusted Community Rate Proposal Modifications for Contract Year 2004 (A-06-06-00094)
8. Partnership Review -- Oklahoma Health Care Authority's Report on Hospice Covered Drugs for Dually Eligible Beneficiaries (A-06-06-00102)
1. Review of Hospital Wage Data Used To Calculate Inpatient Prospective Payment System Wage Indexes (A-01-05-00504)
OIG’s objectives were to (1) consolidate the results of their reviews of 21 hospitals' compliance with Medicare requirements for reporting wage data and (2) identify possible Centers for Medicare and Medicaid Services (CMS) remedies to address reporting errors. The hospitals reported inaccurate wage data totaling $377.9 million, which affected both the numerator and/or denominator of their wage rate calculations.
OIG recommended that CMS develop a corrective action plan to address hospitals' errors in reporting wage data. As part of its action plan, CMS should consider: (1) ensuring that its fiscal year (FY) 2007 wage indexes were adjusted, and its FY 2008 wage indexes will be adjusted, as appropriate, to account for the inaccurate wage data identified in OIG’s individual reviews; (2) working with its fiscal intermediaries to encourage hospitals to implement review and reconciliation; (3) alerting its fiscal intermediaries to the results of OIG’s reviews and recommending that they consider those results in prioritizing areas to examine in future cost report reviews; and (4) working with its fiscal intermediaries to develop techniques for identifying hospitals at high risk of reporting inaccurate wage data and instructing the intermediaries to conduct more detailed reviews at those hospitals. CMS agreed.
To access the full article, cick here: http://oig.hhs.gov/oas/reports/region1/10500504.pdf
2. Audit of Air Ambulance Claims Paid to Covenant Health System During Calendar Year 2002 (A-06-06-00046)
The objective of this audit was to determine whether 100 air ambulance claims for which Covenant Health System (Covenant) received payment during calendar year 2002 were allowable in accordance with Medicare reimbursement requirements.
Covenant improperly billed the Medicare program for air ambulance services for 24 of the 100 sample claims, resulting in Medicare overpayments totaling $15,183 during calendar year 2002. Specifically, Covenant improperly billed for air transportation that was not documented as medically necessary and appropriate (14 claims), mileage beyond the nearest hospitals with appropriate facilities to treat the patients (6 claims), inaccurate mileage (3 claims), and rotary wing transport when fixed wing transport was provided (1 claim).
OIG recommended that Covenant refund to the Medicare program $15,183 in overpayments it received for air ambulance services during calendar year 2002. In written comments, Covenant stated that it had a physician perform a medical review of the improperly billed claims, and, as a result, disagreed with two of their four findings: (1) air transportation that was not documented as medically necessary and appropriate and (2) mileage beyond the nearest hospital with appropriate facilities to treat the patient. Although Covenant provided a summary of the physician’s review, it did not provide additional medical records to support its position. OIG continues to believe that Covenant should refund the entire $15,183.
To access the full article, cick here: http://oig.hhs.gov/oas/reports/region6/60600046.pdf
3. Review of the Management of Unobligated Funds Provided by Title I of the Ryan White Comprehensive AIDS Resources Emergency Act (A-02-03-02006)
The audit objective was to determine whether HRSA complied with departmental policy limiting the carryover of unobligated Title I funds to one budget period.
HRSA did not always comply with departmental policy that, during the audit period, limited the carryover of unobligated grant balances to the next budget period only. Specifically, for grant years 1999-2003, HRSA authorized 46 of the 51 eligible areas to carry over unobligated Title I funds totaling $45,138,339 for periods ranging from 2 to 5 years beyond the original budget period. These funds, which were originally awarded to eligible areas to provide services during a specific budget period, were instead carried over for use in subsequent budget periods.
Departmental policy guidance issued after the audit period now permits the carryover of unobligated grant funds into either of the next two budget periods, but into no other subsequent period.
OIG recommended that HRSA comply with current departmental policy guidance related to the carryover of unobligated grant balances. HRSA concurred with the recommendation and stated that it now follows current departmental policy regarding the approval of carryover requests from Title I grantees.
To access the full article, cick here: http://oig.hhs.gov/oas/reports/region2/20302006.pdf
4. Audit of Lebanon Repatriation Program Funds (A-01-07-02501)
In July 2006, the Department of State notified the Administration for Children and Families (ACF) of an imminent emergency repatriation from Lebanon. Under the Lebanon Repatriation Program (the Program), ACF offered temporary assistance to repatriates at four ports of entry located in Georgia, Maryland, New Jersey, and Pennsylvania.
OIG’s objectives were to determine (1) how ACF expended Program funds and (2) whether ACF followed Federal requirements in reimbursing States for their administrative costs and in seeking recovery of temporary assistance costs from repatriates.
ACF did not always follow Federal requirements in reimbursing States for their administrative costs or in seeking recovery of temporary assistance costs from repatriates. As of December 6, 2006, ACF had reimbursed Pennsylvania for $125,211 in estimated, rather than actual, administrative costs, contrary to Federal guidance. In addition, ACF had not submitted bills for 239 temporary assistance loans totaling $135,344 that Federal regulations require repatriates to repay.
OIG recommended that ACF: (1) obtain a refund from Pennsylvania for $125,211 in estimated administrative costs, (2) provide the Program Support Center (PSC) with all necessary information on temporary assistance loans and direct PSC to bill repatriates for outstanding loans, (3) ensure that States are aware of the requirement to provide adequate documentation for claimed administrative costs, and (4) implement written monitoring procedures to ensure that PSC bills for temporary assistance costs that repatriates owe the Federal Government. ACF generally agreed with OIG’s recommendations.
To access the full article, cick here: http://oig.hhs.gov/oas/reports/region1/10702501.pdf
5. Audit of New Mexico’s Title IV-E Contracted University Training Costs for the 2-Year Period Ended September 30, 2002 (A-06-06-00045)
The New Mexico Children, Youth and Families Department (the State agency) contracted with three State universities to provide a portion of its Title IV-E training needs. OIG’s objective was to determine whether the Federal share of the three universities’ Title IV-E training costs claimed by the State agency was allowable, supported, and allocated in accordance with Federal requirements.
For the 2 years ended September 30, 2002, the State agency claimed $4,625,600 (Federal share) of allowable and $1,188,154 (Federal share) of unallowable or unsupported Title IV-E training costs. In addition, the State agency claimed $47,734 for one university that incorrectly computed administrative costs using an unsupported indirect-cost rate.
OIG recommended that the State agency: (1) refund $1,188,154 to the Federal Government, (2) work with the Administration for Children and Families to identify the allowable portion of the $47,734 in indirect costs allocated to the Title IV-E program, (3) implement procedures to adequately review university contracts and amend the contracts as necessary to comply with Federal requirements that limit administrative costs to the 50-percent administrative rate when the requirements of 45 CFR § 235.64 are not met, and (4) implement procedures to more closely monitor university billings to ensure that universities bill only for costs that are allowable and supported in accordance with program requirements. The State agency partly agreed.
To access the full article, cick here: http://oig.hhs.gov/oas/reports/region6/60600045.pdf
6. Testimony Given by Inspector General Daniel R. Levinson
Testimony was given by Daniel R. Levinson, Inspector General, before the U.S. House of Representatives Ways and Means Subcommittees on Health and Oversight on Medicare Program Integrity.
To get to the testimony: http://oig.hhs.gov/testimony/docs/2007/030807tmy.pdf
7. Tenet Choices 65's Adjusted Community Rate Proposal Modifications for Contract Year 2004 (A-06-06-00094)
The objective of this review was to determine whether Peoples Health Network’s (Peoples Health) use of its payment increase was adequately supported and allowable in accordance with the Medicare Prescription Drug, Improvement, and Modernization Act (MMA). Peoples Health’s use of its MMA payment increase was adequately supported and allowable under the MMA. Peoples Health appropriately used the increased Medicare capitation payments to reduce beneficiary cost sharing, enhance benefits, and stabilize beneficiary access to providers. Specifically, Peoples Health eliminated physical therapy and vision hardware copayments, reduced copayments on prescription drugs, waived member enrollment fees for the prescription drug discount card, and increased the percentage of premiums passed through to providers.
To access the full article, cick here: http://oig.hhs.gov/oas/reports/region6/60600094.pdf
8. Partnership Review -- Oklahoma Health Care Authority's Report on Hospice Covered Drugs for Dually Eligible Beneficiaries (A-06-06-00102)
This review was conducted in partnership with the Oklahoma Health Care Authority Management and Audit Services Division, an internal audit organization of the Oklahoma Health Care Authority (OHCA). The objective of the review was to determine whether OHCA made inappropriate Medicaid payments to Reavis Super Drug for prescription drugs that Valley Hospice identified as prescriptions that it should cover for dually eligible beneficiaries. During the period January 1 through December 31, 2003, Reavis Super Drug billed Medicaid and received payment for 60 prescription drug claims that Valley Hospice should have paid for because the drugs were related to the beneficiaries’ terminal illness.
OHCA recommended that it reimburse the Federal share of the identified overpayments of $3,680 to the Centers for Medicare and Medicaid Services within 60 days of the closure of this review and that Reavis Super Drug (1) reimburse OHCA the $3,680, (2) perform an internal review on amounts billed and Medicaid payments received subsequent to the end of OIG’s review period and return any self-identified overpayments to OHCA, and (3) bill the hospice provider for the overpayment amount reimbursed to OHCA.
To access the full article, cick here: http://oig.hhs.gov/oas/reports/region6/60600102.pdf
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