The watchdogs for HHS have unveiled their agenda for the fiscal year that started last week, leaving providers and their lawyers to sort out which items are new and then guess which ones are likely to generate imminent knocks on their doors.
The 111-page document, officially titled Office of the Inspector General Work Plan Fiscal Year 2008, includes a few dozen new areas of interest, including Joint Commission oversight, payments for X-rays, Medicare bad debt and Medicare disproportionate share payments. HHS officials declined to comment on the plan.
The Work Plan is almost a wish list, said health lawyer Andrew Ruskin, a partner in Morgan, Lewis & Bockius in Washington. Sometimes those wishes dont come true, and items disappear without yielding reports or investigations.
The bad debt issue was chewed over in federal court recently, with the 6th U.S. Circuit Court of Appeals saying the CMS was right to reject Battle Creek (Mich.) Health Systems contention that sums more than 120 days old were uncollectible, because the bills were still being pursued by an outside collection agency. The government is going to be emboldened by that particular case, Ruskin said.