OI G 2007 Work Plan OI G 2007 Work Plan Part II: Physician Focus Part II: Physician Focus HCCA Audio Conference Series November 2, 2006 12:00 Central Time 1 Speakers Speakers Kimberly Zeoli, CPA Kimberly Zeoli, CPA Partner, National Life Sciences & Health Care Regulatory Consulting Practice Partner, National Life Sciences & Health Care Regulatory Consult ing Practice Deloitte & Touche LLP Deloitte & Touche LLP 200 Berkeley Street, Boston, MA 02118 200 Berkeley Street, Boston, MA 02118 617 617- -437 437- -3467 3467 Email: kzeoli@deloitte.com Email: kzeoli@deloitte.com Paul C. Levy, MD Paul C. Levy, MD Compliance Program Medical Director & Acting Chairman, Department of Medicine t of Medicine Compliance Program Medical Director & Acting Chairman, Departmen University of Rochester Medical Center University of Rochester Medical Center 601 Elmwood Avenue, Box 520, Rochester, NY 14642 601 Elmwood Avenue, Box 520, Rochester, NY 14642 585 585- -275 275- -8538 8538 Email: Paul_Levy@URMC.Rochester.edu Email: Paul_Levy@URMC.Rochester.edu Howard J. Young, Esq. Howard J. Young, Esq. Partner, Health Care Practice Group Partner, Health Care Practice Group Sonnenschein Nath & Rosenthal LLP Sonnenschein Nath & Rosenthal LLP 1301 K Street, N.W. Suite 600, East Tower, Washington, DC 20005 1301 K Street, N.W. Suite 600, East Tower, Washington, DC 20005 202 202- -408 408- -9210 9210 Email: hyoung@sonneschein.com Email: hyoung@sonneschein.com 2 1
Session Agenda Session Agenda Overview of the OIG Overview of the OIG Overview of the 2007 Work Plan Overview of the 2007 Work Plan • Risk Areas for Physicians and Physician Risk Areas for Physicians and Physician • Practices: Practices: � Recurring Work Plan Studies Recurring Work Plan Studies � � What What’ ’s New s New � � Q&A Q&A � Closing Remarks Closing Remarks HY 3 Overview of the OIG Overview of the OIG Program Office of Audit Services (OAS) – conducts financial and performance audits of HHS Audits programs and operations to determine whether objectives are being achieved, which aspects of programs need to be performed more efficiently, and to identify systemic weaknesses that give rise to fraud, waste or abuse. Program Office of Evaluation and I nspections (OEI ) – seeks to improve HHS program I nspections effectiveness and efficiency by conducting inspections to provide timely, useful, and reliable information and advice to decision makers. These inspections are program and management evaluations that focus on specific issues of concern to the Department, Congress, and the public. I nvestigative Office of I nvestigations (OI ) – conducts investigations of fraud and misconduct to Focus Areas safeguard HHS’s programs and protect its beneficiaries. OI concentrates its resources on criminal investigations, but its activities are also aimed at deterring fraud and abuse by identifying systemic weaknesses and vulnerabilities that can be mitigated through corrective management actions, regulation, or legislation. Legal Counsel Counsel to the I nspector General (OCI G) –coordinates OIG’s role in the judicial Focus Areas and administrative resolution of fraud and abuse cases involving HHS programs. OCIG also develops and promotes industry specific voluntary compliance program guidance. OCIG issues special fraud alerts to the public, special advisory bulletins, and advisory opinions regarding the application of the OIG’s sanction authorities. OCIG is responsible for developing new, and modifying existing, safe harbor regulations under the anti-kickback statute. HY 4 2
Overview of the 2007 Work Plan Overview of the 2007 Work Plan Significance of the Work Plan Significance of the Work Plan � Work Plan is a Valuable Tool as indication Work Plan is a Valuable Tool as indication � of areas of potential concern of areas of potential concern � Not necessarily a Not necessarily a “ “Fraud Fraud” ” Roadmap Roadmap � � A A “ “Plan Plan” ” for where OIG will invest its for where OIG will invest its � resources in coming year (may change) resources in coming year (may change) � Audit or Evaluation plans get cancelled Audit or Evaluation plans get cancelled � HY 5 Overview of the 2007 Work Plan Overview of the 2007 Work Plan � 93 pages, published 9/25/06 � 93 pages, published 9/25/06 � Four sections: � Four sections: 1. Centers for Medicare & Medicaid Services Number of Work Plan Projects (359 total) 2. Public Health Agencies: Agency for Health Care Research & Quality (AHRQ), Centers for Disease 11 Control and Prevention (CDC), Food and Drug 47 Administration (FDA), Health Resources and Services Administration (HRSA), Indian Health 48 Service (IHS), National Institutes of Health (NIH), and Substance Abuse and Mental Health Services Administration (SAMHSA) 253 3. Administration for Children & Families (ACF) and Administration on Aging (AoA) 4. Department-wide Projects that cut across CMS PHA ACF/AoA Dept-wide programs, including State and local government use of Federal funds, and the functional areas of the Office of the Secretary HY 6 3
Overview of the 2007 Work Plan Overview of the 2007 Work Plan CMS CMS Medicare (126) Medicaid (86) Other (41) Medicare (126) Medicaid (86) Other (41) � Hospitals (25) Hospitals (25) � Administration (34) Administration (34) � Information System Controls (18) Information System Controls (18) � � � � Part D Administration (19) Part D Administration (19) � Prescription Drugs (15) Prescription Drugs (15) � Medicare/Medicaid Hurricane Response (9) Medicare/Medicaid Hurricane Response (9) � � � � Contractor Operations (18) Contractor Operations (18) � Other Services (13) Other Services (13) � Legal Counsel (7) Legal Counsel (7) � � � Physicians and Other Health Long Term and Community Care (11) General Administration (5) � � Physicians and Other Health � � Long Term and Community Care (11) � General Administration (5) � Professionals (17) Professionals (17) Mental Health Services (7) Investigations (2) � Mental Health Services (7) � � Investigations (2) � � Nursing Homes (10) � Nursing Homes (10) � Hospitals (3) � Hospitals (3) � � Part B Drug Reimbursement (10) Part B Drug Reimbursement (10) � � State Children State Children’ ’s Health Insurance s Health Insurance � � Managed Care (9) Managed Care (9) Program (3) Program (3) � � Other Services (7) Other Services (7) � � Home Health (6) Home Health (6) � Medical Equipment and Supplies (5) Medical Equipment and Supplies (5) � � Hospice (2) Hospice (2) � HY 7 Compliance Retrospective: Compliance Retrospective: Where have we been? Where have we been? Key Events: Key Events: 1995 1995 - - University of Pennsylvania $30 million University of Pennsylvania $30 million • • PATH settlement PATH settlement Clarification of components of E/M codes Clarification of components of E/M codes • • Compliance Program Guidance: Compliance Program Guidance: • • Laboratories, Hospitals, Third Third- -Party Billing Party Billing Laboratories, Hospitals, Companies, etc. Companies, etc. PL 8 4
Compliance Efforts: Compliance Efforts: Where are things headed? Where are things headed? Shift in themes of audits Shift in themes of audits • Less attention to Less attention to “ “what what” ” • • More attention to More attention to “ “why why” ” • • Medical necessity reviews Medical necessity reviews • Quality and Outcome Assessments: Quality and Outcome Assessments: • Hospital Hospital • • Physician Physician • • Pay for Performance Pay for Performance • PL 9 Recurring Work Plan Studies Recurring Work Plan Studies PL 10 5
Recommend
More recommend
