The Department of Health and Human Services Office of Inspector General (OIG) just released its Work Plan for the 2015 fiscal year and it contains information that skilled nursing facilities (SNFs) will find useful. The Work Plan describes specific areas and entities that the OIG will be focusing on, including Medicare, Medicaid, hospitals and skilled nursing facilities. Because part of the Work Plan involves actions that will affect SNFs, managers of these facilities should review the Plan to see how it could impact their communities. Furthermore, while interest rates remain, low skilled nursing facilities that are seeking capital to acquire additional properties or for other reasons, should contact Cambridge Realty Capital to learn more about the many different financing options that it offers for a wide variety of senior housing transactions.

Details from the Work Plan

According to the Work Plan, one of the areas OIG will focus on more aggressively next year is the how billing is done for Medicare Part B services that are associated with nursing homes and providers. OIG will do this by conducting studies that will examine billing patterns in a number of different service categories. The goal of these mini-audits is to identify and stop irregular and incorrect billing practices. OIG is taking this action at the express direction of Congress whose members want to ensure that Medicare payments are only being issued for legitimate services. In order to avoid any issues with OIG during these mini-audits, skilled nursing facilities should do their best to make sure that their billing practices are in order.

OIG will also determine if State survey agencies are verifying the correction plans they received from nursing homes that were cited for deficiencies during their recertification surveys. Under federal law, when a nursing home is cited for a deficiency during a survey, it has to prepare a correction plan and submit it to its State survey agency or the Centers for Medicare & Medicaid Services (CMS). The survey agency must then follow up to confirm that the cited facility took corrective action to address whatever deficiency or deficiencies they had. In the past, state agencies have not always done this and that is why OIG has decided to make this an area of emphasis in fiscal year 2015.

Lastly, a provision in the Affordable Care Act requires the Secretary of Health and Human Services to oversee a program for States to conduct background checks on prospective employees of nursing facilities and other long-term care providers who have direct access to patients and residents. The Affordable Care Act also requires OIG to evaluate this program and to report its findings to Congress. OIG has begun evaluating aspects of the program and in fiscal year 2015, it will continue this work and will release its findings to Congress after its evaluation is complete. In light of this, skilled nursing facilities should make sure that they are in compliance with the various rules and regulations that pertain to hiring employees, especially the rules that involve background checks.

These are just a few of the areas that OIG will be focusing on going forward. Managers of skilled nursing facilities and other long-term care providers who are interested in learning more about OIG’s plans for the 2015 fiscal year, should consider reviewing the Work Plan to see if there is additional information in it that could benefit them.

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