2017 OIG Work Plan Holds Few Surprises for Labs

There are few surprises in the Health and Human Services Office of Inspector General's 2017 Work Plan. The OIG's annual Work Plan provides a summary of new and continuing reviews that the agency is undertaking to protect the integrity of, and find opportunities to improve the efficiency of, U.S. Health and Human Services programs. The OIG revises the work plan midway through the year as well.

Here are some highlights of the issues the OIG addresses that laboratories and pathologists will be concerned about:

• Although listed as a new item, the OIG's mandatory review of implementation of the Protecting Access to Medicare Act of 2014 (PAMA) is actually a returning item. The OIG issued its latest report on this topic just a few months ago in September. Once again, the OIG will provide an update on the status of the Centers for Medicare & Medicaid Services (CMS) efforts to implement PAMA as well as its annual analysis of the top 25 laboratory tests based on Medicare payment.

• The OIG continues to review histocompatibility laboratories and whether payments for these labs' services complied with Medicare.

• A long time feature of the OIG's Work Plans, independent clinical laboratory billing requirements continues to make the list of OIG concerns. The agency will carry on its review of Medicare payments to independent clinical laboratories— specifically, looking for labs that "routinely submit improper claims."

• In addition to its focus on PAMA, the OIG also includes a new item reviewing CMS implementation of the Quality Payment Program under the Medicare Access and CHIP Reauthorization Act (MACRA). The OIG indicates it will address "timelines and key milestones CMS has established" for implementation as well as "key challenges and potential vulnerabilities CMS is facing during implementation."

Takeaway: Labs continue to receive attention in the OIG's annual Work Plan but only in continuing projects.