Unreasonable Employee Compensation
OIG says it will review hospital salary data to "determine the potential impact on the Medicare Trust Fund if the amount of employee compensation that could be submitted to Medicare for reimbursement on future cost reports had limits."
The report adds that employee compensation should represent "reasonable remuneration for managerial, administrative, professional and other services relate to the operation of the facility and furnished in connection with patient care." Currently there are no limits on what hospitals can include.
Hospital Billings for Clinic Care
OIG will examine the impact on payments to hospitals that are increasingly buying free-standing clinics and physician practices, which enables hospitals to bill at higher rates.
Hospitals Billing for "New" Patients
The OIG says that its "preliminary work identified overpayments that occurred because hospitals used new patient codes when billing for services to established patients." It will investigate hospital-based clinics that inappropriately bill Medicare higher rates for "new" beneficiary visits when those patients had been seen within the prior three years.
Inpatient Compounding Pharmacies
OIG will dig into how well state agencies and accreditation agencies perform in their oversight of hospital compounding pharmacies.
Staff Physician Performance
OIG intends to determine whether hospitals participating in Medicare and their governing bodies have a system to periodically appraise members of their medical staff, as they're required to do, including verification of credentials and review of the National Practitioner Databank. "Robust hospital privileging programs contribute to patient safety," the work plan states.
Hurricane Sandy Preparedness
OIG will seek to determine whether hospitals in selected counties hit by Hurricane Sandy met a required level of preparedness and response. The OIG work plan specifically asks about the hospitals' "participation in disaster programs funded by the CDC to meet conditions of participation required for Medicare reimbursement.