A biweekly publication from the Healthcare Group at Feeley & Driscoll, P.C.
Please visit us at OIG’s 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 Quality Improvement Organization in Iowa (A-07-06-01035)
2. Review of Virginia's Compliance With the 'Reimbursement of State Costs for Provision of Medicare Part D Drugs' Demonstration Project Requirements (A-03-07-00001)
3. Medicare Part D Prescription Drug Plan (PDP) Sponsor Internet Web Sites: Content and Accessibility (OEI-06-06-00340)
4. A Comparison of Medicare Program and Consumer Internet Prices for Power Wheelchairs (OEI-04-07-00160)
1. Review of Quality Improvement Organization in Iowa (A-07-06-01035)
The Senate Finance Committee requested that OIG assess the fiscal integrity of the Medicare Quality Improvement Organizations with respect to six specified fiscal integrity areas.
Of the $10.3 million of costs reviewed, $9.6 million appeared reasonable for Federal reimbursement. Of the remaining costs, the Iowa Foundation for Medical Care (IFMC) incurred $208,974 of costs that were unallowable and $530,822 of costs that may not have complied with Federal requirements.
OIG recommended that IFMC (1) refund $179,358, which includes $145,091 of direct costs and $34,267 of associated indirect costs, for unallowable food and equipment; (2) reduce the indirect cost pool by $29,616 for chartered air travel costs incurred by board members; and (3) work with the CMS contracting officer to determine what portion of the $530,822 incurred for board member fees, board member travel costs, and executive compensation during the OIG’s audit period should be excluded from the indirect cost pool for purposes of determining final rates. IFMC disagreed with the recommendations.
To view the full report, click here: http://www.oig.hhs.gov/oas/reports/region7/70601035.pdf
2. Review of Virginia's Compliance With the 'Reimbursement of State Costs for Provision of Medicare Part D Drugs' Demonstration Project Requirements (A-03-07-00001)
The OIG’s objective was to determine whether the Commonwealth of Virginia complied with the CMS “Reimbursement of State Costs for Provision of Part D Drugs” demonstration project requirements related to reimbursed drug claims for full benefit dual eligible beneficiaries. Virginia complied with CMS’s demonstration project requirements related to reimbursed drug claims for dual eligible beneficiaries. The OIG is not submitting recommendations to Virginia.
To view the full report, click here: http://www.oig.hhs.gov/oas/reports/region3/30700001.pdf
3. Medicare Part D Prescription Drug Plan (PDP) Sponsor Internet Web Sites: Content and Accessibility (OEI-06-06-00340)
This evaluation found that 33 percent of the 84 PDP sponsor Web sites reviewed did not contain all federally required content. The most commonly omitted information pertained to enrollee disenrollment rights and responsibilities, the potential for PDP contract termination, and information related to the formulary. Using two electronic tools that enable page-level testing of Web-based information and applications, the OIG also found that 85 percent of sponsor Web sites did not meet at least one of the Federal requirements for Web site accessibility. These problems could affect access to content by Medicare beneficiaries.
To view the full report, click here: http://www.oig.hhs.gov/oei/reports/oei-06-06-00340.pdf
4. A Comparison of Medicare Program and Consumer Internet Prices for Power Wheelchairs (OEI-04-07-00160)
In 2004, OIG found that Medicare and its beneficiaries paid higher prices for power wheelchairs than consumers or suppliers. In November 2006, CMS implemented a revised fee schedule for power wheelchairs as part of a strategy to reform Medicare payments for power wheelchairs. The revised fee schedule was designed to improve the accuracy of Medicare pricing for power wheelchairs. However, the new fee schedule amounts have been criticized by some suppliers of power wheelchairs as too low to cover their cost of providing the power wheelchairs to Medicare beneficiaries.
The OIG collected and analyzed prices of power wheelchairs from the Internet sites of power wheelchair suppliers during the first quarter of 2007. The OIG then compared the median Internet prices of power wheelchairs to the Medicare fee schedule amounts during the same time period. In addition, the OIG calculated the potential savings to Medicare and its beneficiaries during the first quarter of 2007 had power wheelchair claims submitted to Medicare been reimbursed at the median Internet prices the OIG collected.
The OIG found that Medicare fee schedule amounts for power wheelchairs were 45 percent higher than median Internet prices available to consumers in the first quarter of calendar year 2007. Medicare and its beneficiaries could have achieved savings during the first quarter of 2007 had power wheelchairs been reimbursed at median Internet prices available to consumers. On average, each beneficiary could have saved $233 of his or her power wheelchair copayment. The most frequently ordered procedure code (K0823) accounted for 68 percent of total potential savings to Medicare and its beneficiaries.
The OIG concluded that consumers were able to purchase most power wheelchairs over the Internet at lower prices than the Medicare fee schedule amounts for the same power wheelchairs.
The OIG recommend that CMS consider performing additional reviews to determine whether the current Medicare power wheelchair fee schedule amounts for certain groups and procedure codes are too high. CMS concurred with the OIG’s recommendation. OIG work is continuing in this area. The OIG plans to conduct further evaluations to compare Medicare fee schedule amounts to actual prices paid by suppliers.
To view the full report, click here: http://www.oig.hhs.gov/oei/reports/oei-04-07-00160.pdf
5. Review of Separately Billed Composite Rate Laboratory Services Under the Medicare End Stage Renal Disease Program at Caritas St. Elizabeth’s Medical Center (A-01-07-00506)
The OIG’s objective was to determine whether Caritas St. Elizabeth's Medical Center (the Hospital) billed Medicare in accordance with Medicare requirements for laboratory tests provided to end stage renal disease (ESRD) beneficiaries during calendar years (CY) 2004 and 2005. The OIG found that the Hospital did not always bill Medicare in accordance with Medicare requirements for laboratory tests provided to ESRD beneficiaries.
Specifically, the Hospital incorrectly billed for (1) hematology laboratory services included in the composite rate, (2) automated multi-channel chemistry tests that did not meet specific reimbursement requirements, and (3) ferritin tests performed beyond the allowable frequency without medical justification. Based on the results of a statistical sample, the OIG estimated that Medicare overpaid the Hospital $61,628 for laboratory services provided to ESRD beneficiaries during CYs 2004 and 2005.
The OIG recommended that the Hospital refund the Medicare Program $61,628 in overpayments for CYs 2004 and 2005, identify and refund any Medicare payments for ESRD-related laboratory services received after the OIG’s audit period that did not meet Medicare requirements and strengthen its policies and procedures to ensure compliance with Medicare requirements. The Hospital agreed with the OIG’s findings and recommendations.
To view the full report, click here: http://www.oig.hhs.gov/oas/reports/region1/10700506.pdf
For the List of Excluded Individuals/Entities (LEIE), follow this link:
http://oig.hhs.gov/fraud/exclusions/listofexcluded.html
For the index of recent they 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. |
