February 19, 2018

Imaging and Radiation Oncology Services Appear in 2018 HHS Inspector General Work Plan

Imaging and radiation oncology projects appear in the HHS Office of Inspector General’s (OIG) 2018 Work Plan. Why does that matter to ACR members?

The OIG operates under Congress’ mandate to review health care-related programs and operations. The Work Plan represents the OIG's annual "playbook" of current and upcoming investigations, audits, and reports. These include health care arrangements OIG may believe costs too many dollars or could violate federal fraud and abuse laws. Members who render patient care in the areas listed in the Work Plan should not expect an immediate knock on their office door or inbox from the OIG. However, it could happen.

OIG continues to audit the Food and Drug Administration’s approach to timely communicating and resolving a cybersecurity vulnerability of a networked medical device. Networked medical devices include radiology systems. OIG believes that such devices increasingly threaten the privacy and security of patient health information and patient safety.

Intensity Modulated Radiation Therapy (IMRT) also remains on OIG’s radar. OIG indicates that it will analyze Medicare outpatient payments to IMRT to assess whether they complied with Federal requirements. In 2016, ACR noted that OIG may have focused on claims that were submitted years ago, to compare with more recent claims that had to account for IMRT coding revisions. The regulators might have changed their audit approach to look at a new range of data.

OIG still audits how Medicare pays for non-physician services under the Part A Inpatient Prospective Payment System (IPPS). It states that prior reviews uncovered “significant overpayments” to hospital outpatient providers for non-physician services provided shortly before or during beneficiary inpatient stays. Therefore, OIG plans to assess whether national Medicare payments to those providers were accurate for non-physician outpatient services provided within three days before the date of admission, on the date of admission or during IPPS stays (excluding date of discharge). OIG notes that inpatient operating costs include ancillary services such as radiology services. OIG Active Work Plan

Notably, OIG also has listed two projects focusing on CMS’ Open Payments database. In one inspection, OIG will review the nature and number of financial interests related to prescription drugs and DME/prosthetic/orthotic equipment and supplies. OIG separately will audit the database to determine the degree of missing or inaccurate data and how well CMS oversees manufacturers’ and group purchasing organizations’ compliance with reporting requirements. It will assess whether the required data for payments to physicians and teaching hospitals is valid. ACR members should check the Government’s Open Payments database to learn whether any payments they receive from manufacturers appear on it. Review the database