Each year, the Office of the Inspector General (OIG) at the Department of Health and Human Services publishes a summary of its activities and a work plan for the coming year. What follows is a summary of new topics in the FY2017 work plan that may be of interest to urologists. For the full report, go to bit.ly/OIG2017.
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As a reminder, the OIG is the investigative and enforcement arm of HHS and its programs, including but not limited to the Centers for Medicare & Medicaid Services (CMS) and the FDA. Its Office of Audit Services and Office of Evaluation and Inspections are among several branches charged with maintaining the integrity of HHS programs and watching out for those programs’ beneficiaries. According to its website (bit.ly/HHSOIGhome), HHS OIG is the largest Inspector General office in the federal government, with 1,600 employees devoted to fighting waste, fraud, and abuse in the agencies’ 100 or so programs—including Medicare. The primary tools used by the OIG are forced exclusion from HHS programs, civil monetary penalties for violations including kickback and physician self-referral issues, and criminal prosecutions of individuals and businesses for fraud and other egregious acts.
According to its downloadable database, as of December 2016, out of a total of 66,042 exclusions, 6,829 physicians and 24 urologists have been excluded from federal programs by the OIG. (One urologist who appeared in the data in 2015 has been removed from the data.) The top two reasons for exclusions are licensing issues and conviction of program-related crimes.
What follows are areas of OIG scrutiny in 2017 of which urologists should be aware.
Intensity-modulated radiation therapy
The OIG believes outpatient payments for IMRT services need to be reviewed to be sure those payments (and associated billings) were in accordance with requirements. Urologists who bill for IMRT services in their integrated practices should take note.