OIG June 2019 Work Plan Updates

PUBLISHED: Jun 24, 2019
Relevant to: All Healthcare Organizations

The Office of the Inspector General (OIG) recently released updates to their work plan. In 2017, OIG transitioned from a yearly to a monthly Work Plan with the goal of enhancing transparency around OIG's continuous work planning efforts. The OIG Work Plan provides insight into areas where government enforcement and audit officials are focusing.

For June 2019, the follow selection of OIG Work Plan activities are of interest to healthcare organizations:

Opioid Use in Medicare Part D in 2018

According to OIG, the opioid crisis remains a public health emergency. In 2017, 47,600 opioid-related overdose deaths occurred in the United States. Identifying patients who are at risk of overdose or abuse is key to addressing this crisis. This data brief will provide 2018 data on Part D spending for opioids, as well as on beneficiaries who received extreme amounts of opioids through Part D and those who appeared to be doctor shopping. It will also provide data on prescribers who ordered opioids for large numbers of these beneficiaries.

Operational take-away: Providers’ opioid practices are under increased scrutiny. Documentation of the clinical justification for opioid prescriptions is a key prescribing practice.

Review of Medicare Part B Claims for Intravitreal Injections of Eylea and Lucentis

Medicare Part B covers ophthalmology services that are reasonable and necessary for the diagnosis or treatment of illness or injury or to improve the functioning of a malformed body member. Ophthalmology services include intravitreal injections of Eylea and Lucentis to treat eye diseases such as wet age-related macular degeneration. Medicare pays for an intravitreal injection (which is considered a minor surgery) as part of a global surgical package that includes the preoperative, intraoperative, and postoperative services routinely performed by the physician. Medicare pays for Eylea and Lucentis separately from the intravitreal injection. Chapter 12, section 40.1 of the Centers for Medicare & Medicaid Services' Medicare Claims Processing Manual states that separate payment can be made for other services provided by the same physician on the same day as the global surgery if the services are significant and separately identifiable or unrelated to the surgery.OIG will review claims for intravitreal injections of Eylea and/or Lucentis and the other services billed on the same day as the injection, including evaluation and management services, to determine whether the services were reasonable and necessary and met Medicare requirements.

Operational take-away: Clinical documentation must be clear and accurate and, when applicable, should demonstrate that services provided on the same day as a global surgery package are clinically justifiable and separate/unrelated to the surgery.

See the OIG Work Plan recently added items to review all the items added to the work plan this month. Included with today’s notice are example policies related to the above OIG activities.

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