OIG Work Plan 2017 adds E/M, financial relationships to the watch list

by: Julia Kyles, CPC Nov 10, 2016

Providers who offer chronic or transitional care management services should take note of the latest work plan from the HHS Office of Inspector General (OIG). These services are two of the six new Work Plan targets that are likely to impact physicians and non-physician providers who bill Medicare Part B.

The OIG is likely to look beyond claims for chronic care management (99490) and transitional care management (99495-99496). The summaries for both items note that other Medicare-covered services can’t be billed during the care management service period. The OIG gave examples of the types of services, which might provide additional insight into where the agency will direct its attention. For chronic care the OIG listed transitional care management, home health care supervision, hospice care and certain end-stage renal disease services. For transitional care the examples included chronic care management, and prolonged services without direct patient contact.

Other new items in the work plan include:

Connect the dots between Medicare payments and physician financial relationships. The OIG will go compare open payments program data to Medicare payment data to determine “the volume and total dollar amount” Medicare paid for drugs and durable medical equipment ordered by doctors who had financial relationships with manufactures and group purchasing organizations.
A mandatory review of payments for lab tests. The review of the top 25 lab tests by Medicare payment is required by the Protecting Access to Medicare Act of 2014. In addition, the agency will check up on how CMS’ is handling the implementation of the new payment system for clinical lab tests that is designed to bring Medicare’s lab payments in line with private payer reimbursement.

Providers should also take a look at items from previous versions of the work plan, since their presence indicates the OIG is still interested. Leftover items include:

Anesthesia services.
Home visits.
Prolonged care services.

Blog Tags: compliance, OIG

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