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2014 Work Plan for SNFs, Hospice & Home Health Services

If you are a physician and want to know the specific initiatives in the OIG’s 2014 Work Plan applicable to you, check out the post from earlier this week. Today, we will be examining the OIG’s enforcement priorities for skilled nursing facilities (“SNF”), hospice, and home health services.


Based upon prior OIG audits and research, the OIG found that SNFs were responsible for a large number of billing errors and that SNFs increasingly bill for the highest level of therapy even though beneficiary characteristics remain largely unchanged. The OIG will review SNF’s billing practices and describe the variations in billing for selected years.

As part of a continued initiative, OIG will still focus on the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting.


The OIG will examine the extent to which hospices serve Medicare beneficiaries, who reside in assisted living facilities (“ALFs”), by scrutinizing the length of stay, level of care, and common terminal illnesses of beneficiaries.

In addition, the OIG plans to review hospice inpatient care for appropriateness of claims, election statements, and level of hospice care.

Home health services

The 2014 Work Plan did not announce any new initiatives related to home health services, but the OIG will continue to review various aspects of the home health prospective payment system, including Medicare’s documentation requirements. In addition, the OIG will continue to monitor the extent to which home health agencies are complying with state requirements for conducting criminal background checks on applicants and employees.

The OIG Work Plan is a great source of information and good indicator of where the OIG will devote its resources. When preparing internal audits and identifying compliance priorities, entities should ensure key risk areas identified by the OIG are part of their internal review.  If you have any questions about the 2014 Work Plan, contact a McBrayer health care attorney today.

This article is intended as a summary of newly enacted federal and state law and does not constitute legal advice.

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