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OIG Releases Work Plan For Fiscal Year 2011

The Office of the Inspector General recently released the Work Plan for fiscal year (FY) 2011. The Work Plan describes areas the OIG will focus on in the upcoming year; something all practitioners concerned with compliance should pay attention to.  Medical devices, radiation therapy quality and safety, and an expanded focus on the three and one day payment windows are all covered.

Part of the focus for FY 2011 is on quality and billing concerns.  In particular, brachytherapy reimbursement, replacement of devices received at no cost or reduced cost, safety and quality of intensity-modulated radiation therapy (IMRT) and the safety and quality of image guided radiation (IGRT) are areas receving increased scrutiny.  When it comes to billing issues, particularly for a difficult billing area such as medical devices, providers need to be aware of the correct procedure.  Conducting a thorough and in depth compliance audit of a provider’s billing procedures is a smart and effective way to make sure that office practices do not run afoul of proper procedures.

With respect to the payment window rules, the Work Plan has added a one day payment window for non-IPPS facilities.  This rule is akin to the three day payment window available to IPPS facilities and it requires payments to non-IPPS facilities for diagnostic services provided the day before an inpatient claim to be included, along with other services related to admission on the day before admission, as part of the inpatient claim.

Several other topics are also on OIG’s watch list for FY 2011.  These include provider status, observation services for outpatient services, Part A hospital capital payment, critical access hospitals, Medicare disproportionate share payments, duplicate graduate medical education payments, hospital readmissions with conditions coded present-on-admission, inpatient rehabilitation facility transmissions of patient assessment instruments and Medicare excessive payments.

If you would like more information regarding compliance in any of the areas identified in the OIG Work Plan, please contact a Wachler & Associates attorney at 248-544-0888 or visit our websites at and

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