Last week, the Office of the Inspector General (OIG) released its 2010 Federal Work Plan, which sets forth various projects that will be addressed during the fiscal year by the Office of Audit Services, Office of Evaluation and Inspections, Office of Investigations and Office of Counsel to the Inspector General. Included in the plan for 2010 are items of note for sleep medicine physicians and professionals in the sleep field.
1. Appropriateness of Medicare Payments for Polysomnography
“We will examine the appropriateness of Medicare payments for sleep studies. Sleep studies are reimbursable for patients with symptoms consistent with sleep apnea, narcolepsy, impotence, or parasomnia in accordance with the CMS “Medicare Benefit Policy Manual,” Pub. No. 102, ch. 15, § 70. Medicare payments for polysomnography increased from $62 million in 2001 to $215 million in 2005. We will also examine the factors contributing to the rise in Medicare payments for sleep studies and assess provider compliance with Federal program requirements. (OEI; 00-00-00000; expected issue date: FY 2011; new start)”
2. Enrollment Standards for Independent Diagnostic Testing Facilities
“We will review IDTFs enrolled in Medicare to determine whether they meet Medicare’s enrollment standards. Pursuant to Federal regulations at 42 CFR § 410.33, IDTFs, which received payments of approximately $1 billion in 2007, are required to certify on their enrollment applications that they comply with 14 standards. Such standards include, among others, requirements that IDTFs be in compliance with all applicable Federal and State licensure and regulatory requirements for the health and safety of patients, provide complete and accurate information on their enrollment applications, and have technical staff on duty with the appropriate credentials to perform tests. (OEI; 00-00-00000; expected issue date: FY 2010; new start)”
3. Physician Self-Referral for Durable Medical Equipment Services
“We will review Medicare payments for DME services to determine their allowability in context of Federal requirements for physician self-referral prohibitions in the Social Security Act, § 1877. Specifically, sections 1877(a)(1) and 1877(a)(2) provide that unless exceptions apply, physicians are prohibited from making referrals for furnishing designated health services to entities with which the physicians have financial relationships. Designated health services identified under the physician self-referral prohibition include DME services. We will determine the allow ability of physician self-referrals to DME suppliers in which physicians held ownership interests. (OAS; W-00-10-35503; various reviews; expected issued date: FY 2010; new start)”