HHS Office of Inspector General 2009 Work Plan

The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently released its Work Plan for Fiscal Year 2009. The Work Plan outlines various ongoing and planed reviews for the upcoming year. The Work Plan provides valuable insight into the program areas that the OIG will target for audits and investigations. The 2009 Work Plan increasingly focuses OIG efforts and budget on the Medicare and Medicaid programs. Because Congress and the new Presidential administration will be closely reviewing Medicare expenditures in 2009 to identify potential savings to pay for health care coverage expansion, the OIG’s audit work this year carries even greater importance. There are two items in the Work Plan dealing with independent diagnostic testing facilities (IDTFs) and ultrasound services as they relate to Medicare.

OIG wrote:

Geographic Areas With a High Density of Independent Diagnostic Testing Facilities

We will review services and billing patterns in geographic areas with high concentrations of independent diagnostic testing facilities (IDTF). An IDTF is a facility that performs diagnostic procedures and is independent of a physician’s office or hospital. It may have a fixed location or be a mobile entity, and the practitioner performing the procedures may be a nonphysician. IDTFs must meet performance requirements at 42 CFR § 410.33 to obtain and maintain Medicare billing privileges. A 2006 OIG review found numerous problems with IDTFs, including noncompliance with Medicare standards and potential improper payments of $71.5 million. In areas with a high density of IDTFs, we will examine service profiles, provider profiles, beneficiary profiles, and billing patterns.

(OEI; 00-00-00000; expected issue date: FY 2010; new start)

Patterns Related to High Utilization of Ultrasound Services

We will review services and billing patterns in geographic areas with high utilization of ultrasound services paid under the MPFS. The Social Security Act, § 1848(a)(1), establishes the MPFS as the basis for Medicare reimbursement for all physician services, including ultrasound services, and section 1862(a)(1)(A) provides that Medicare will pay for services only if they are medically necessary. In areas of high utilization of ultrasound services, we will examine service profiles, provider profiles, and beneficiary profiles.

(OEI; 01-08-00100; expected issue date: FY 2009; work in progress)