Tuesday, April 1, 2014

OIG Compendium of Priority Recommendations

Dianne De La Mare

The US Department of Health and Human Services (HHS), Office of Inspector General (OIG) has released a core publication, Compendium of Priority Recommendations (Compendium), which used to be titled Compendium of Unimplemented Recommendations. The Compendium identifies significant recommendations described in previous OIG reports with respect to problems, abuses or deficiencies for which corrective actions have not been completed. Further, the Compendium lists OIG’s top 25 unimplemented recommendations, that it believes would best protect the integrity of HHS programs if implemented.

Some of the recommendations that apply directly to our profession include:
  • Improve controls to address improper payments to SNFs (Inappropriate Payments to SNFs Cost Medicare More Than $1 Billion in 2009 and Questionable billing by SNFs);
  • Detect and recover improper Medicare payments for services to incarcerated, unlawfully present or deceased individuals (Medicare Improperly Paid Providers Millions of Dollars for Incarcerated Beneficiaries Who Received Services During 2009 Through 2011 and Medicare Payments Made on Behalf of Deceased Beneficiaries in 2011);
  • Maximize recovery of Medicare overpayments (Obstacles to Collection of Millions in Medicare Overpayments and Collection Status of Medicare Overpayments Identified by Program Safeguard Contractors);
  • Ensure that Medicare Advantage Organizations are implementing programs to prevent and detect waste, fraud and abuse (Medicare Advantage Organizations’ Identification of Potential Fraud and Abuse);
  • Improve care planning and discharge planning for beneficiaries in nursing facility settings (Plans for Care and Discharge—Skilled Nursing Facilities Often Fail to Meet Care Planning and Discharge Planning Requirements)
  • Address harm to [SNF] patients, questionable resident hospitalizations and inappropriate drug use (Adverse Events in SNFs: National Incidence Among Medicare Beneficiaries, Medicare Nursing Home Resident Hospitalization Rates Merit Additional Monitoring and Drug Utilization—Medicare Atypical Antipsychotic Drug Claims for Elderly Nursing Home Residents);
  • Improve [Nursing Facility] emergency preparedness and response (Emergency Preparedness—Gaps Continue to Exist in Nursing Home Preparedness and Response During Disasters);
  • Address Medicaid managed care fraud and abuse concerns (Medicaid Managed Care: Fraud and Abuse concerns Remain Despite Safeguards);
  • Ensure that [Medicaid home- and community-based care settings] service providers comply with quality and safety requirements (Medicaid—Oversight of Quality of Care in Medicaid Home- and Community-Based Services Waiver Programs); and
  • And Reduce improper payments and fraud (US Department of Health and Human Services Met Many Requirements of the Improper Payments Information Act of 2002 But Was Not Fully Compliant).
You can obtain a copy of the entire Compendium go to OIG’s website.

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