OIG Work Plan Monthly Review: August 2017

Two months into its new monthly update regime, the OIG added 4 new items to its Work Plan in August, none of which will have a direct impact on laboratory services. However, 3 of the initiatives may have an indirect effect on at least some labs.

1. Part B Payments for Psychotherapy Services
Red Flag: The Work Plan update cites an earlier OIG review finding that Medicare Part B psychotherapy services payments were "particularly problematic" and that Medicare paid for services that were not covered, inadequately documented, or medically unnecessary.

What OIG Will Investigate: The OIG will review Part B payments to determine whether they were allowable under Medicare documentation requirements.

2. Medicare Payments for Ventilation Devices
Red Flag: Ventilation devices aren't competitively bid the way some devices are. And Medicare reimbursement for ventilation devices has risen from $51 million in 2011 to $72 million in 2015.

What OIG Will Investigate: The OIG will determine the reasonableness of the Medicare fee schedule prices for ventilation devices compared to prices on the open market to identify potential wasteful spending.

3. Duplicate Drug Claims for Hospice Beneficiaries
Red Flag: Previous OIG work (A-06-10-00059) found that Medicare may have paid twice for prescription drugs for hospice beneficiaries, once under the Part A per diem rate and again under Part D.

What OIG Will Investigate: The OIG says it intends to follow up on this work and review 2 things:

• Whether Part D drug claims for individuals who receive hospice benefits under Part A are appropriate; and

• Whether Part D is continuing to pay for prescription drugs that should have been covered under the per diem payments made to hospice organizations.

Takeaway: Although none of the new OIG initiatives directly involve lab services, you need to be aware of them if you're involved in providing any of the affected goods and services to Medicare, Medicaid or other government health program beneficiaries.