Payment Matters

October 10, 2007

OIG Rolls Out its 2008 Work Plan: What Should Providers Be Aware Of?

By: Kristin Cilento Carter

The Office of Inspector General (OIG) issued its annual Work Plan on October 1, 2007. The Work Plan provides a broad description of the focus areas for the OIG in the coming fiscal year. It serves as an important tool, providing a roadmap to potential risk areas. Providers should evaluate their compliance programs to determine if the current program should be modified to incorporate any of the OIG focus areas for 2008. Some of the areas listed in the 2008 Work Plan are summarized below.

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OIG Approves Hospital's Payments to Physicians for On-Call Services

By: Christine M. Morse

The Department of Health and Human Services Office of Inspector General ("OIG") issued an advisory opinion on September 20, 2007, in which the OIG indicated that it would not impose sanctions against the requestor, a hospital that has developed an arrangement to compensate physicians for on-call coverage. The hospital had historically faced difficulty in securing on-call coverage from physicians in various specialties. The hospital, a not-for-profit with a charitable mission to provide services to the indigent, operates an emergency department ("ED") that, in accordance with state law, always remains open and accepts patients regardless of their ability to pay. Due to various factors, including the financial burden of providing uncompensated patient care and malpractice insurance costs, local physicians had grown reluctant to provide on-call coverage or follow-up care for patients who had presented in the ED. The hospital consequently developed a program to compensate physicians for providing on-call and indigent care services.

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Two or Three Times May Be the "Charm" in Correcting Deficiencies. But It Will Also Be Costly

By: John F. Lessner and Emily H. Wein

On September 19, 2007, CMS issued a final rule that established "revisit user fees." These fees may be charged to health care facilities for revisit surveys, i.e., surveys conducted after an initial certification, recertification or substantiated complaint survey that identified deficiencies. The revisit user fees will affect only those providers or suppliers for which CMS identified deficient practices and that required a revisit to assure corrections have been made. CMS estimates that this new provision will generate approximately $37 million to offset the costs of the Medicare survey and certification programs.

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Gina Eliadis
Creative and New Media
410.230.7051
gmeliadis@ober.com

 

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