The OIG has released the 2017 Compendium of Unimplemented Recommendations, summarizing prioritized recommendations relating to HHS programs and operations.   Topping the list are recommendations relating to hospitals, including:

  • Reimbursement rates for critical access hospital swing beds should be adjusted to the lower rates for similar services provided in skilled nursing facilities.
  • Reimbursement rates for hospital outpatient department procedures should be adjusted to the lower rates for similar procedures conducted in ambulatory surgical centers.
  • Medicare should adopt a hospital transfer payment policy to lower hospital reimbursement for beneficiaries who are discharged early to hospice care.
  • CMS and the Agency for Healthcare Research and Quality should take steps to reduce harm to patients in rehabilitation hospitals.
  • CMS should increase protections for beneficiaries under the 2-midnight policy that applies to hospitals decisions about a beneficiary’s inpatient or outpatient admission status.
  • The disparity in beneficiary coinsurance for outpatient services received at a critical access hospital versus an acute-care hospital should be reduced.

Among its top 25 priorities is OIG’s recommendation that CMS reform hospice payments to reduce the incentive for hospices to target beneficiaries with certain diagnoses and those likely to have long stays.  In addition, it recommends changes the way Medicare pays skilled nursing facilities for therapy services to reduce costs and align services with beneficiary needs.

Also among these priorities is the recommendation that ONC and CMS develop a comprehensive plan to address fraud vulnerabilities in electronic health records.  Several top OIG recommendations relate to Medicare Advantage organizations and Part D sponsor, including:

  • CMS should prevent enrollment of unlawfully present beneficiaries in Medicare Advantage organizations and Part D sponsors.
  • To combat prescription drug abuse, including opioid abuse, CMS should encourage Part D sponsors to implement new authority to restrict certain beneficiaries to a limited number of pharmacies or prescribers.
  • CMS should collect comprehensive data from Part D plan sponsors to improve its oversight of their efforts to identify and investigate potential fraud and abuse.

The top-25 also include OIG recommendations to CMS relating to state Medicaid programs, to FDA to ensure food facilities correct serious violations identified during FDA inspections, to the Administration for Children and Families, and to the Indian Health Service.  HHS-wide recommendations include having a department-wide system to share information about problematic grantees, developing an improper-payment estimate for the Temporary Assistance for Needy Families program, and reducing the improper payments estimate for the Medicare Fee-for-Service and Medicaid programs.