Cracking Down on Fraud and Waste: OIG Releases Recommendations to Increase HHS Program Efficiency
In March of 2014, the Office of the Inspector General ("OIG") released the "OIG Compendium of Priority Recommendations." The recommendations offered are designed to help current programs for the Department of Health and Human Services ("HHS") run more effectively. The recommendation discussed twenty-five "opportunities" which, if addressed, would help to eliminate fraud and waste among HHS programs. The “opportunities” include the following:
Medicare Policies and Payments:
The recommendations seek to address known issues regarding Medicare policies and payments through:
- Improved Medicare billing controls for community mental health centers, home health agencies and skilled nursing facilities.
- Enhanced detection and recovery of improper benefits paid to those in jail, deceased, or unlawfully present in the country.
- Increased efforts to improve detection and recovery of overpaid Medicare benefits.
Medicare Quality of Care and Safety Issues
The recommendations seek to address known issues regarding Medicare quality of care and safety issues via:
- More diligent tracking and identification of adverse events in hospitals and nursing homes and assurance that any remedial efforts by the hospitals are effective in reducing such events.
- Improved detection and oversight of improper drug use and inappropriate residential hospitalizations in nursing homes.
- Oversight of hospice providers to ensure compliance with Medicare requirements.
Medicaid Program Policies and Payments
The recommendations seek to address known issues regarding Medicaid Program policies and payments by:
- Ensuring state Medicaid claims do not improperly inflate federal reimbursements.
- Overseeing states' implementation of programs to detect and prevent fraud and returning fraudulently obtained money to the federal government.
Oversight of Food Safety Issues
The recommendations seek to address known issues regarding oversight of food safety issues through:
- Improved surveillance and oversight of dietary supplements. It is further recommended that FDA inspections be done and documented and that civil penalties be levied against anyone who fails to comply.
HHS Grants and Contracts
The recommendations seek to address known issues regarding HHS grants and contracts with:
- Improved oversight of grantees, including quality standards and identifying conflicts of interest.
- Greater focus on HHS financial audits, with further steps to correct deficiencies discovered in the audits.
The general scope and concern of the compendium is the need to increase oversight and reduce fraud and waste. So what can you do as a provider? Make sure that everything is appropriately documented and accounted for. The targeted areas focus on the need for systems to be in place for detecting and eliminating improper claims. It is important to review your compliance plan and the policies that you have in place to ensure that they are adequate for discovering improper benefits and fraud. The goal is to eliminate spending which results from false and improper claims. Anything you can do to prevent and minimize such claims will be helpful in avoiding adverse consequences and legal fees spent in defense of alleged violations if the new recommended policies are implemented.
Jennifer has particular expertise in health law and she represents providers with emphasis in the areas of physicians, hospice, home care and long term care, including one of the country’s largest long-term care organizations. She has a vast array of experience in teaming with providers in the areas of regulatory compliance and contracts.View All Posts by Author ›
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Best Lawyers® 2020
Congratulations to the attorneys of the Health Care practice group at Foster Swift Collins & Smith, PC for their inclusion in the Best Lawyers in America 2020 edition. Firm-wide, 42 lawyers were listed. Best Lawyers lists are compiled based on an exhaustive peer-review evaluation and as lawyers are not required or allowed to pay a fee to be listed; inclusion in Best Lawyers is considered a singular honor. Health Care practice group members listed in Best Lawyers are as follows:
- Gilbert M. Frimet, Southfield
- Richard C. Kraus, Lansing
- Gary J. McRay, Lansing
- Jack A. Siebers, Grand Rapids/Holland
- Jennifer B. Van Regenmorter, Holland
To see the full list of Foster Swift attorneys listed in Best Lawyers 2020, click here.