In this episode, we are joined by Mary Devine, Senior Director of Revenue Cycle Services at BESLER, to discuss recent additions to the OIG Work Plan and their impact on providers.
Highlights of this episode include:
- What open items and additions to the OIG Work Plan should providers know about?
- How has COVID-19 impacted the OIG work plan?
- Why the surge in hospital visits due to COVID-19 has impacted the transfer rule.
- What providers can do to avoid being audited.
- And more…
Mike Passanante: Hi, this is Mike Passanante and welcome back to the award-winning Hospital Finance Podcast®. Recently Mary Devine, who is a Senior Director of Revenue Cycle Services here at BESLER, delivered a webinar on the latest OIG work plan. And Mary is going to highlight a few of those areas for us today on the podcast. Mary, welcome to the show.
Mary Devine: Thank you for having me.
Mike: So let’s talk about some of the impact that COVID has had on the OIG work plan. I think one of the first things that has come up is the impact to nursing homes. Why don’t you tell us about that?
Mary: Sure. As we all know, there has been a huge focus on nursing homes from the pandemic perspective and really focusing on the containment of the COVID-19 since it was widespread in the nursing homes. So the OIG certainly has added a number of items through the work plan as it is focused on skilled nursing facilities. And one of the big areas that they did– CMS has begun requiring all nursing homes to report to CMS and to their state and local health authorities on any breakouts or any patients that are diagnosed with COVID-19. And that must be done on a weekly basis. So the OIG is going in and auditing that. They’re going in and actually going to report on whether the nursing homes are reporting to CMS or not. So they’re going to review if there are any patients with COVID-19 diagnosed in a certain time period. And then they’re going to make sure that those patients have, in fact, been reported appropriately to CMS and to the local and state authorities. So that is the first one that has most recently hit in June of 20. Just recently. Then the other one that they’re doing is they are focused on the containment. So they’re going to focus on how the nursing homes are controlling the patients in and out from a perspective with the COVID-19. So they’re going to be auditing some of the infection control as it relates to the nursing homes and making sure there is no spread.
Mike: And likewise, laboratories have been affected by COVID-19, of course. What’s going on there?
Mary: And that’s a really big one from the perspective of the add-on test. So through the COVID-19 in PHE, they waived the requirement for physician ordering of the COVID-19 tests. And so what’s happening is they are seeing a high increase in add-ons. You can do multiple tests on one specimen. So what they’re going to go in is audit the number of COVID-19 tests and then the add-on tests that are done for the rollout. And so they’re going to make sure that there is no fraud and abuse going on from or the overuse of the COVID-19 and the add-on. And in addition to that, it’s very important to note that with that whole waiver of eliminating the need for a physician order to perform the COVID-19 test, they’re also waiving the physician conclusion as it relates to a diagnosis. So in the past, you could never diagnose from a lab test but with the onset of the blanket waiver that came out, not only does the physician not have to order the test, but the physician does not have to diagnose it, so you can diagnose right from that lab test.
Mike: Mary, one might expect that with the surge in hospital visits due to COVID and the movement of patients in and out of different care settings, there was an impact to the transfer rule and it’s something that they’re looking at. What’s going on there?
Mary: So from a COVID perspective and all the blanket waivers that came out, and this is unrelated to the work plan, but I think very important to mention, is that there are going to be a lot of patients transferring because the whole intent is to have patients with the COVID in a hospital setting together and then patients that do have the diagnosis of COVID they are in separate units. So they’re allowing hospitals to transfer patients much faster between distinct part units and even nonclinical areas to house patients with COVID or that do not have COVID. So when you think about the transfer rule you want to make sure that you are really tracking whether that patient is discharged or not because you may have patients that are impacted by the rule and really shouldn’t be. But one of the things that I wanted to point out as it relates to the work plan and Transfer DRG rule is that they had accounts impacted by the transfer laws as kind of a blanket rule that they were going to be focusing on patients with a discharge status code of an 01 and an 04 because there were patients that were being transferred to home but really did receive post-acute care and should not have been paid that full DRG and OIG had advised CMS that they needed to correct these audits, excuse me, their edits in their system. So they went ahead and have corrected those edits and as fast as they close that one Transfer DRG rule review they reopened one in March of ’20 to go in and make sure that those edits are actually functioning. So it opened in the same format on the OIG work plan and this is now really there to test that these edits were in fact corrected that if a claim gets submitted as an 01 and there is post-acute care provided that the claim would reject. And one of the things that we’re finding in the work that we do from a Transfer DRG perspective for our providers, Palmetto has overcorrected their edits and they are rejecting many claims where there is not a post-acute care provided, but the claim is getting rejected, so we’re battling that with Palmetto. So just some real important stuff to think about as you do a review for Transfer DRG.
Mike: And if you are an acute care hospital and you’d like a safety net review of your Transfer DRG claims that is certainly work that we do here at BESLER and Mary leads that team up. So feel free to drop us a note at firstname.lastname@example.org to get more details on how you can get started with that.
Additionally, as I mentioned at the beginning of the podcast, Mary recently delivered a large webinar on the OIG work plan with a lot of detail that goes beyond what we talked about here today. So feel free to go up to Besler.com, go to the Insights page, click on Revenue Cycle, and you will see a link to that webinar along with the associated slides. Mary, thanks so much for joining us today on the podcast and talking about a few of the key elements that are contained in the latest OIG work.
Mary: Happy to do it.