Medicare Update

OIG Work Plan Reveals Possible Risk Areas for Medicare Providers and Suppliers

On October 1, 2009, the Department of Health and Human Services' Office of Inspector General (OIG) released its Work Plan for fiscal year 2010 (Work Plan).

The Work Plan addresses the areas and issues the OIG intends to audit, evaluate and inspect during fiscal year 2010.  The Work Plan also provides some insight into the areas and issues that may evolve into future OIG enforcement activities. Therefore, health care providers and suppliers should consider the Work Plan in relation to their operations.

This post briefly highlights some of the Work Plan priorities for hospitals, physicians and other health care providers with respect to Medicare Parts A and B. Work Plan priorities for Medicare provider and supplier types not addressed in this post (e.g., home health agencies) will be covered in subsequent posts.

CMS Adds Health Information Technology Pages to Website

The Centers for Medicare & Medicaid Services recently added health information technology pages to its website, which pertain to the American Recovery and Reinvestment Act of 2009. Among other things, the pages provide information related to Medicare and Medicaid incentives for electronic health records adoption and links to the Department of Health and Human Services website.

CMS Releases Fact Sheet on ARRA and Electronic Health Records

On June 16, 2009, the Centers for Medicare & Medicaid Services released a Fact Sheet entitled Medicare and Medicaid Health Information Technology: Title IV of the American Recovery and Reinvestment Act.

Among other things, the Fact Sheet highlights the Medicare payment incentives for eligible professionals and hospitals that are meaningful electronic health record users. The Fact Sheet also contains a Frequently Asked Questions (FAQ) section, which includes, among others, the following FAQ:

Question: When will the Centers for Medicare & Medicaid Services (CMS) publish regulations to define certified Electronic Health Records and "meaningful use?"

Answer: CMS intends to publish a proposed rule in late 2009 to define meaningful use of certified Electronic Health Records (EHR) technology and establish criteria for the incentives programs.  We are working extensively with the Office of National Coordinator for Health Information Technology (ONC) to identify the proposed criteria.

On June 16, 2009, the meaningful use working group of the HIT Policy Committee also released its recommendations for a definition of "meaningful use" of electronic health records.  Information on the recommendations, which do not appear to provide a formal definition, can be found here. Also see the Department of Health and Human Services' Press Release.

The FAQs also provide CMS's timeline related to the incentive program based on the current implementation plan.  See the Fact Sheet for more information.