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December 15th, 2014
The HHS OIG Work Plan for the 2015 Fiscal Year has recently been released. In this publication, the OIG addresses the accomplishments made from the previous year's Plan as well as the objectives that will be of interest for the coming new year.
Accomplishments for the 2014 Fiscal Year are reported to be a whopping $4.9 billion in expected recoveries. This includes approximately $834.7 million in audit receivables and about $4.1 billion in investigative receivables. Additionally, the OIG reports approximately $15.7 billion in estimated savings for the 2014 Fiscal Year due to legislative, regulatory, or administrative actions that were supported by OIG recommendations.
Additionally, the 2014 Fiscal Year accomplishments report 4,017 exclusions of individuals and entities from participation in Federal health care programs; 971 criminal actions against individuals or entities, and 533 civil actions which includes actions for things such as false claims, Civil Monetary Penalties and administrative recoveries related to provider self-disclosure.
Of course, the numbers above are not specific to chiropractic as they do encompass all provider types and specialties submitting claims to federal programs. Note too that the source of these recoveries, savings and penalties listed are the combined statistics from the multiple federal programs in place that are designed and intended to fight fraud, waste and abuse of federal healthcare dollars.
To further address why these numbers are significant to chiropractic, first recognize that the OIG focus on chiropractic continues to expand as time progresses. Not to suggest that chiropractic is specifically being targeted. Thorough review of the OIG report clearly indicates the expansion of attention to various specialties and provider types. This expansion of focus is a result of the statistics noted above, the success of and significant expansion of programs in place to fight fraud, waste and abuse.
Importantly, though this report specifically addresses Federal programs, providers that are submitting claims to any third party carrier should use this information. Private payers and other non-federal programs also recognize the success of the efforts of the HHS OIG and they too, continue to implement and enforce audits, reviews and other investigations with the objective of preventing fraud, waste and abuse of those programs. These statistics above serve as incentive for practices to take appropriate protective and preventative measures for their own understanding and compliance with coding, billing and documentation guideline as well as other related regulation.
Given this information, there is no better time to address Compliance in your practice. Compliance planning does allow for practices to address priority areas first and to implement a Program that is custom to each individual office. Contact ChiroCode for questions, support or help with creating, implementing, updating or training for your practice compliance.
Reference: https://oig.hhs.gov/reports-and-publications/archives/workplan/2015/FY15-Work-Plan.pdf
Brandy Brimhall CPC, CMCO, CCCPC, CPCO
