What they're looking for: OIG outlines risk areas
According to its compliance program guidance for hospitals, the federal Office of the Inspector General (OIG) expects that your hospital's written policies and procedures should be used as a basis for "appropriate training and educational programs."
These programs, the OIG says, should emphasize the agency's "areas of special concern," which it claims to have identified through its investigative and audit functions. These risk areas include the following:
w billing for items or services not actually rendered;
w providing medically unnecessary services;
w unbundling;
w billing for discharge in lieu of transfer;
w patients' freedom of choice;
w credit balances - failure to refund;
w hospital incentives that violate the anti-kickback statute or other similar federal or state statute or regulation;
w joint ventures;
w financial arrangements between hospitals and hospital-based physicians;
w Stark physician self-referral law;
w knowing failure to provide covered services or necessary care to members of a health maintenance organization;
w patient dumping.
According to the OIG, "Additional risk areas should be assessed as well by hospitals and incorporated into the written policies and procedures and training elements developed as part of their compliance programs."
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