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The Office of Inspector General (OIG) released its Work Plan for Fiscal Year 2015 (2015 Work Plan) last week. The 2015 Work Plan lays out the projects and investigations that the OIG plans to tackle throughout the year and provides insight into the focus areas of the OIG in its efforts to identify and prevent fraud, abuse and waste in healthcare. Healthcare providers can use the annual OIG work plans to assess compliance with the areas of concern to the OIG, as well as to provide advance notice of the provider’s activities that may be reviewed by the OIG.

The 2015 Work Plan indicates that the OIG will be reviewing independent clinical laboratory billing practices. In particular, the OIG intends to specifically identify clinical laboratories that submit improper claims and will recommend to the Centers for Medicare and Medicaid Services (CMS) the recovery of overpayments. The 2015 Work Plan references past audits, investigations and inspections where the results have shown that some independent clinical laboratories are not in compliance with Medicare billing requirements.

It is likely that the 2015 Work Plan is referring, at least in part, to a report issued in 2014 by the OIG entitled, Questionable Billing for Medicare Part B Clinical Laboratory Services, which provided recommendations for CMS to investigate and prevent fraudulent billing practices. This report was planned as part of the OIG’s Work Plan for Fiscal Year 2014. The OIG also issued a special fraud alert this year entitled Laboratory Payments to Referring Physicians which dealt with compensation paid by laboratories to physicians and group practices for blood specimen collection, processing and packaging activities, as well as the submission of patient data to a database or registry.

The OIG expects to complete its review of independent clinical laboratory billing practices in 2015. In recent years, the OIG and CMS have been scrutinizing laboratory billing. Reviewing the OIG work plans and subsequent reports can help a provider anticipate risk areas and make changes to its current practices, as well as predict areas where there may be payment cuts.

For more information, please contact:

Bridget C. Howard 

Richard S. Cooper

Jane Pine Wood 

McDonald Hopkins has a large and diverse healthcare practice, which is national in scope. The firm represents a wide variety of healthcare providers, facilities, vendors, technology companies and associations. Our diverse experience enables us to give our clients a unique perspective on the issues that may confront them in the rapidly evolving healthcare environment.