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. Provider Enrollment, Chain and Ownership System: Early Implementation Challenges (OEI-07-05-00100)
2. Review of Pension Costs Claimed for Medicare Reimbursement by Arkansas Blue Cross Blue Shield for Fiscal Years 1997 Through 1998 (A-07-06-00208)
3. Review of Medicare Contractor's Pension Segmentation Requirements at Arkansas Blue Cross Blue Shield and Pension Plan Termination (A-07-06-00206)
4. Review of Missouri Provider Tax (A-07-06-01029)
1. Provider Enrollment, Chain and Ownership System: Early Implementation Challenges (OEI-07-05-00100)
This report assesses the early implementation of the Provider Enrollment, Chain and Ownership System (PECOS) related to the timely processing of Medicare provider enrollment applications and system access. OIG found that because of misinterpretation of the Centers for Medicare & Medicaid Services (CMS) guidance, the majority of Part A applications contractors reported as exceeding timeframes as of July 31, 2005, had not actually exceeded timeframes.
Sixty-six percent of the Part A applications reported as exceeding the 99-percent processing timeframe had not actually exceeded it. The misclassification was due to the fact that contractors retained applications awaiting tie-in notices in pending inventory or failed to update the record status in the PECOS correctly. Part B applications contractors reported as exceeding timeframes as of July 31, 2005, were primarily the result of one contractor’s backlog and providers’ failure to respond to requests for information. Lastly, half of all contractors reported experiencing difficulty accessing the PECOS and obtaining and recertifying user identification (ID) numbers.
OIG conclude that CMS could conduct updated training for Part A contractor staff to ensure consistent understanding of application-processing policy. CMS may also want to address issues with system access and user IDs that could lead to future delays in application processing. Additionally, CMS may want to determine the need for increased system capacity to ensure that periods of limited access to the PECOS will not reoccur as planned initiatives, such as the National Provider Identifier and enrollment of Medicaid providers, are implemented. Finally, CMS could revise the Enterprise User Administration Workflow process to prevent user ID requests and recertifications from being denied because of factors such as incorrect approver e-mail addresses, approvers being on leave, or approvers not acting upon e-mails. CMS indicated in its comments that the information in the report will assist in its ongoing management of the PECOS, but believes that the startup issues noted have been resolved.
To access the full article, click here: http://www.oig.hhs.gov/oei/reports/oei-07-05-00100.pdf
2. Review of Pension Costs Claimed for Medicare Reimbursement by Arkansas Blue Cross Blue Shield for Fiscal Years 1997 Through 1998 (A-07-06-00208)
The objective of OIG’s review was to determine the allowability of pension costs that Arkansas claimed for Medicare reimbursement for fiscal years (FY) 1997 through 1998. Arkansas claimed $126,636 of unallowable Medicare pension costs for FYs 1997 through 1998 primarily because of the use of the Financial Accounting Standard No. 87 expense for the calculation of the "Other" segment allowable pension costs. Arkansas claimed $2,454,110 of pension costs for Medicare reimbursement; however, OIG calculated the allowable Medicare pension costs during this period to be $2,327,474.
OIG recommended that Arkansas revise its Final Administrative Cost Proposals for FYs 1997 through 1998 to reduce its claimed pension costs by $126,636. Arkansas agreed with OIG’s recommendation.
To access the full article, click here: http://www.oig.hhs.gov/oas/reports/region7/70600208.pdf
3. Review of Medicare Contractor's Pension Segmentation Requirements at Arkansas Blue Cross Blue Shield and Pension Plan Termination (A-07-06-00206)
The objective of OIG’s review was to determine whether Arkansas complied with the Medicare contract’s pension segmentation requirements while: (1) implementing the prior audit finding; (2) updating Medicare segment assets from January 1, 1996, to May 1, 1999; and (3) determining the excess assets that should be remitted to Medicare as a result of the termination of its defined benefit pension plan. Arkansas properly implemented the prior audit recommendation; however, it did not comply with the Medicare contract’s pension segmentation requirements while updating the Medicare segment’s assets from January 1, 1996, to May 1, 1999.
As a result, Arkansas overstated the Medicare segment assets by $546,859. In addition, Arkansas did not comply with the cost accounting standards in determining Medicare’s share of the excess pension assets as of May 1, 1999. Arkansas calculated and remitted to the Federal Government $1,125,543 as Medicare’s share of the excess pension assets, which is a $16,711 overstatement.
OIG recommended that Arkansas decrease Medicare’s share of the excess pension assets by $16,711, and adjust its Final Administrative Cost Proposal to properly reflect Medicare’s share of the excess assets. Arkansas generally disagreed.
To access the full article, click here: http://www.oig.hhs.gov/oas/reports/region7/70600206.pdf
4. Review of Missouri Provider Tax (A-07-06-01029)
Missouri's provider tax for State fiscal year (FY) 2004 did not comply with the requirements for a permissible provider tax outlined in Federal laws and regulations and the Medicaid Partnership Plan. Missouri did not have policies and procedures to ensure that its provider tax program complied with Federal laws and regulations and the plan. As a result, Missouri's provider tax may have been impermissible.
OIG recommended that Missouri: (1) submit to the Centers for Medicare & Medicaid Services (CMS) a separate waiver test for each class of service for State FY 2004; (2) refund $8,235,595 to the Federal Government; (3) submit to CMS a separate waiver test for each class of service for State FYs 2005 and 2006; (4) refund Federal reimbursement for the unallowable tax amounts paid by the hospitals not included in OIG’s audit and for unallowable Federal reimbursement for State FYs 2005 and 2006; (5) notify CMS of any State changes to the provider tax program; and (6) develop policies and procedures to ensure that the provider tax program complies with all Federal and negotiated requirements for provider taxes when completing the waiver tests. Missouri did not agree with the findings or the recommendations.
To access the full article, click here: http://www.oig.hhs.gov/oas/reports/region7/70601029.pdf
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