News: 2021 OIG top unimplemented recommendations released
The department of Health and Human Services (HHS) has released the 2021 version of its annual publication, the OIG’s Top Unimplemented Recommendations: Solutions To Reduce Fraud, Waste, and Abuse in HHS Programs. This edition focuses on the top 25 unimplemented recommendations that the OIG views would “most positively affect HHS programs in terms of cost savings, program effectiveness and efficiency, and public health and safety if implemented.”
Items in the protecting patients and Medicare Parts A and B recommendations included:
CMS – Protecting Patients (Cross-Cutting)
1. To ensure that nursing homes are implementing actions to prevent the spread of COVID-19 and that they are protecting residents, CMS should:
a. Assess the results of infection control surveys of nursing homes and revise surveys as appropriate.
b. Clarify expectations for states to complete backlogs of standard surveys and high priority complaint surveys suspended in the early months of the pandemic.
2. CMS should take actions to ensure that incidents of potential abuse or neglect of Medicare and Medicaid beneficiaries are identified and reported.
CMS – Medicare Parts A and B
3. CMS should take steps to tie Medicare hospice payments to beneficiary care needs and quality of care to ensure that services rendered adequately serve beneficiaries’ needs.
4. CMS should reevaluate the inpatient rehabilitation facility (IRF) payment system, which could include seeking legislative authority to make any changes necessary to more closely align IRF payment rates and costs.
5. CMS should seek legislative authority to comprehensively reform the hospital wage index system.
6. Related to severe malnutrition claims, CMS should:
a. Recover overpayments of $1 billion resulting from incorrectly assigning severe malnutrition diagnosis codes to inpatient hospital claims.
b. Ensure that hospitals bill appropriately moving forward.
c. Conduct targeted reviews of claims at the highest severity level that are vulnerable to upcoding.
7. CMS should analyze the potential impacts of counting time spent as an outpatient toward the 3-night requirement for skilled nursing facility (SNF) services so that beneficiaries receiving similar hospital care have similar access to these services.
8. CMS should consider seeking legislative authority to implement least costly alternative policies for Part B drugs under appropriate circumstances.
The remaining recommendations can be found in the annual publication. The 25 recommendations come from OIG audits and evaluations issued through December 31, 2020. Because of the evaluation timeframe, it should be noted that many recommendations predate the COVID-19 public health emergency. The OIG states that as of September 21, 2021, it had “58 audits and evaluations underway related to COVID-19 response and recovery, which may result in recommendations that appear in future editions.
Editor’s note: The full OIG Top Unimplemented Recommendations: Solutions To Reduce Fraud, Waste, and Abuse in HHS Programs can be found here.