OIG 2009 Work Plan: Continuing Focus on Dialysis

Abstract

Last fall, the Department of Health and Human Services Office of Inspector General (OIG) announced its 2009 Work Plan (see Table I). This new list of priorities continues the OIG's previously announced focus on payments to dialysis facilities for Epogen, separately billable laboratory services under the ESRD Program, and the use of ambulance services to transport ESRD patients. However, the new plan drops previously announced areas of focus on payments to hospitals for observation services and on the pricing of clinical laboratory tests including tests for ESRD patients. New area of focus separate and apart from general Work Plan item of substantiation of medical justification for Epogen OIG will determine whether facility policies and protocols are intended to drive hemoglobin levels higher than 12 g/dL OIG will focus on the availability of dialysis services at IHS facilities and if services are not available locally, on the distances patients must travel to obtain such services Funding of contract health services and availability of funding during entire budget year will also be examined Of the two new dialysis-related areas of interest, of particular interest is the new area of focus on whether dialysis facilities may be “using dosing guidelines, standards and protocols” for ESAs that are not consistent with the labeling recommendations of the FDA, which warns against dosing of ESAs such that hemoglobin levels exceed 12 g/dL. This new enforcement priority supplements the OIG's prior and continuing emphasis on enforcement of the anemia management guidelines.