On January 31, 2014, the OIG Work Plan For Fiscal Year 2014 was released. Areas pertaining to skilled nursing facilities are the following:
- Medicare Part A billing by skilled nursing facilities (new) – The OIG will describe SNF billing practices in selected years as well as variation in billing among SNFs in those same years. Prior OIG work found that SNFs increasingly billed for the highest therapy level despite the fact that beneficiary characteristics were largely unchanged.
- Questionable billing patterns for Part B services during nursing home stays – The OIG will identify questionable billing patterns associated with nursing homes and Medicare providers for Part B services provided to nursing home residents during stays not paid under Part A. Specific examples could include stays for which benefits are exhausted or the 3-day qualifying stay requirement is not met.
- State agency verification of deficiency corrections – The OIG will determine whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys. Verification will be made through on-site review or by obtaining other evidence of correction in compliance with federal regulations.
- Program for national background checks for long-term-care employees – The OIG will review the procedures implemented by participating States for long-term-care facilities or providers to conduct background checks on prospective employees and providers who would have direct access to residents. The OIG will also determine the costs of conducting the background checks. Additionally, the OIG will study outcomes of the states’ programs, including whether there were any unintended consequences.
- Hospitalizations of nursing home residents for manageable and preventable conditions –The OIG will determine the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting. According to the OIG, these hospitalizations are costly and may include quality of care problems in SNFs.
The intent of the OIG corporate compliance effort is that facility staff will self-audit their performance and ensure its conformity with regulations and applicable laws. Nursing facility personnel can implement quality assurance and performance improvement efforts for each of the five categories to determine if they are in compliance or whether corrective action is needed to be made to processes or systems to ensure that identified problems are addressed and do not recur.