New Medicare Probes May Affect Speech-Hearing Clinicians The federal government will add four new Medicare-related reviews of interest to speech and hearing professionals, in addition to several ongoing reviews, to its 2012 plans. The U.S. Department of Health and Human Service’s Office of the Inspector General (OIG) issues an annual work plan [PDF, 2.1MB] that includes reviews ... Policy Analysis
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Policy Analysis  |   November 01, 2011
New Medicare Probes May Affect Speech-Hearing Clinicians
Author Notes
  • Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.
    Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.×
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Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   November 01, 2011
New Medicare Probes May Affect Speech-Hearing Clinicians
The ASHA Leader, November 2011, Vol. 16, 19. doi:10.1044/leader.PA3.16152011.19
The ASHA Leader, November 2011, Vol. 16, 19. doi:10.1044/leader.PA3.16152011.19
The federal government will add four new Medicare-related reviews of interest to speech and hearing professionals, in addition to several ongoing reviews, to its 2012 plans.
The U.S. Department of Health and Human Service’s Office of the Inspector General (OIG) issues an annual work plan [PDF, 2.1MB] that includes reviews to identify fraud, waste, and abuse and to promote economy, efficiency, and effectiveness.
The four new projects are:
  • Safety and Quality of Post-Acute Care for Medicare Beneficiaries—Focuses on the care and safety of Medicare beneficiaries transferred from acute-care hospitals to post-acute care.

  • Questionable Billing Patterns During Non-Part A Nursing Home Stays—Identifies questionable billing patterns associated with Part B services to residents in skilled nursing facilities.

  • Inpatient Rehabilitation Facilities—Examines the level of physical therapy, occupational therapy, and speech-language treatment provided in inpatient rehabilitation facilities and the amount of concurrent and group treatment.

  • Questionable Billing Characteristics of Home Health Services—Reviews 2010 home health care agency claims with billing characteristics that may indicate potential fraud.

OIG also will continue several ongoing projects:
  • In skilled nursing facilities, OIG is determining the extent to which residents’ plans of care are based on assessments and is reviewing Part A claims for medical necessity, sufficient documentation, and correct coding.

  • A review of home health agencies is determining compliance with payment systems requirements, including the documentation required.

  • OIG is reviewing private-practice physical therapists who have a high utilization rate for outpatient physical therapy services. OIG has already identified claims for services provided by independent physical therapists that were not reasonable, medically necessary, or properly documented. The review of physical therapists signals OIG’s interest in private practices, which could eventually apply to speech-language and other disciplines.

  • OIG is reviewing the performance of Medicare Part A and B recovery audit contractors (RACs; the organizations contracted to identify and recover improper Medicare payments) and Centers for Medicare and Medicaid Services (CMS) oversight of the payment recovery program.

  • Various Medicare contractors establish local coverage determinations (LCDs) that result in differences in Medicare coverage; as a result, a service could be covered in one location, but denied elsewhere. OIG is reviewing these differences, as well as the evidence contractors use to develop their coverage rules, and assessing CMS’s monitoring and oversight of local coverage determinations. Most Medicare contractors have established specific LCDs for speech-language and dysphagia services.

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November 2011
Volume 16, Issue 15