OIG Releases 2014 Work Plan

The Office of the Inspector General (OIG) has released their 2014 work plan and to no one’s surprise, therapy is in the work plan.The OIG will focus on critical access hospitals (CAH’s) and the Medicare beneficiaries cost for outpatient therapy services as well as the cost the Medicare program reimburses for swing beds in a CAH compared to the same service provided in a skilled nursing facility. The OIG will look at inpatient rehabilitation facilities (IRF) and adverse events that occur to Medicare beneficiaries in the IRF setting and determine the extra cost to the Medicare program due to the adverse events.

In the skilled nursing facility (SNF) setting, the OIG will look at Medicare Part A billed by the SNF and will describe SNF billing practices in selected years and will describe variation in billing among SNFs in those years. In addition, the OIG will look at questionable billing patterns for Part B services during nursing home stays.

The OIG will look extensively at chiropractic services in 2014. Area’s of focus will include compiling the results of prior OIG audits, evaluations, and investigations of chiropractic services paid by Medicare to identify trends in payment, compliance, and fraud vulnerabilities and offer recommendations to improve detected vulnerabilities. The OIG will also review Medicare Part B payments for chiropractic services to determine whether such payments were claimed in accordance with Medicare requirements. Lastly, the OIG will determine the extent of questionable billing for chiropractic services. We will also identify trends suggestive of maintenance therapy billing.

For physical therapists in private practice, the OIG will review outpatient physical therapy services provided by independent therapists to determine whether they were in compliance with Medicare reimbursement regulations. Prior OIG work found that claims for therapy services provided by independent physical therapists were not reasonable or medically necessary or were not properly documented. The OIG focus is on independent therapists who have a high utilization rate for outpatient physical therapy services.