| Physicians take notice. The OIG’s 2010 Work Plan | | | | beneficiary profiles and billing patterns. |
| is full of clear enforcement and compliance goals that | | | | In a separate category, the OIG says it will inspect |
| will certainly affect you. | | | | whether IDTFs are in compliance with all applicable |
| There are other issues the OIG will look into that may | | | | Federal and State licensure and regulatory |
| not seem to have much to do with doctors initially. But | | | | requirements for the health and safety of patients, |
| taking a close look at it will help physician practices | | | | provide comprehensive and correct information on |
| gear up for some unexpected compliance issues in the | | | | their enrollment applications, and have technical staff |
| coming year. The key strategies for OIG compliance is | | | | on duty with the right credentials to perform tests. |
| therefore preparation. | | | | EMTALA Review |
| Independent Diagnostic Testing Facilities (IDTFs) and | | | | The OIG is also planning to review CMS’ overnight |
| EMTALA are two issues that feature in this year’s | | | | of hospitals’ compliancewith the Emergency |
| Work Plan. | | | | Medical Treatment and Labor Act (EMTALA). |
| IDTF | | | | Physicians may not take notice of this goal, but they |
| According to the Work Plan, the OIG is interested in | | | | should. |
| two areas concerning IDTFs: Services and billing | | | | According to the Work Plan, a previous OIG review |
| patterns in areas with high concentrations of IDTFs; | | | | raised alarms about long delays to investigate |
| and compliance with the facilities’ Medicare | | | | complaints and inadequate feedback provided to |
| enrollment standards. | | | | hospitals on alleged violations. OIG plans to identify |
| The 2006 OIG reviewdetected several problems | | | | variations among regions in the number of EMTALA |
| pertaining to IDTF. This included noncompliance with | | | | complaints and cases referred to states, examine |
| Medicare standards and potential improper payments | | | | CMS’ methods for tracking complaints and cases, |
| of $71.5 million. In areas with a high density of IDTFs, | | | | and the like. |
| OIG will look into service profiles, provider profiles, | | | | |