Day 2 general session recap: OIG discusses Work Plan, emphasizes documentation requirements
This morning, two Office of Inspector General (OIG) representatives, Truman Mayfield, CPA, CPE, and Scott Perry, CPA, took the stage to discuss the OIG’s Work Plan, audit activities, and offer some words of wisdom (and perhaps consolation) to those under OIG scrutiny.
To kick off the session, Mayfield discussed the ins and outs of the OIG’s various offices, how the Work Plan is developed and updated on a monthly basis, and how the various offices interact and intersect with each other.
“We each have different missions, difference focuses, and we try not to duplicate work, even if it seems like it, we’re coming at the issue from different perspectives,” Mayfield said. “We’re one OIG […] we’re all going in the same direction. […] We want to go beyond just making reports; we want to actually make a difference.”
Mayfield also emphasized that CMS programs (Medicare and Medicaid) take up more than 90% of Health and Human Services (HHS) funds, so inevitably, the OIG focuses most of their efforts on this portion of HHS’ programs, though they do have to ensure oversight of all other programs covered by HHS as well.
“Our OIG Work Plan evolves as [HHS] programs evolve,” he said. “The Work Plan is a living document.”
After covering the basics, Mayfield turned the podium over to Perry to discuss the different types of audits and some background into the methodologies for those audits. Perry emphasized the need for complete and accurate documentation.
The first step in any audit, according to Perry, is a review of all the claims within the target audit period. Then, the OIG reviews the claims and sorts them.
“We flag all claims that have only CC or MCC for an audit automatically,” Perry told attendees, reiterating an oft repeated CDI tip—don’t stop at just one CC or MCC; capture all relevant secondary diagnoses for each claim.
After the initial review, Perry said that the OIG auditors typically spend about a week onsite at the organization reviewing processes and meeting with departments.
“We meet with departments, including CDI, which is always the most enjoyable part of the visit,” he said. “Plus, we like to just hear people brag about their facility and tell us why it’s better than the one down the street.”
After spending time at the organization, the auditors prepare their report to share with the organization before publishing it on the OIG website, offering suggestions for improvement, and allowing the organization time to formulate a response to be published along side the report. Then, the follow up and enforcement is left to CMS, he reminded attendees.
“Just remember, we just present our findings and make suggestions,” he said. “Then CMS makes you pay it back, not us.”
Regardless of the audit findings, Perry said, most stages in the process come down to CDI program’s bread and butter: Documentation. The documentation in the record needs to support the coding he said. Ensuring that piece is correct will make for a much smoother auditing and process and can even help you stay off the OIG’s radar all together.
“Remember,” Perry said, “it all comes down to documentation, documentation, documentation.”