OIG's 2015 Work Plan takes triple aim at imaging services

Certain imaging services continue to be potential targets for the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG), according to the office’s recently published Fiscal Year 2015 Work Plan.

The Work Plan summarizes new and ongoing activities that OIG is planning on pursuing concerning certain HHS programs during current fiscal year and beyond. These programs include several related to radiology and imaging, such as:

• Diagnostic radiology—medical necessity of high-cost tests. The OIG, pointing out that Medicare won’t pay for services that aren’t “reasonable and necessary,” is continuing to review Medicare payments for high-cost radiology tests to determine they have been medically necessary and to the extent the use of these tests has increased.

• Imaging Services—payments for practice expenses. OIG is reviewing Medicare Part B payments for imaging services to “determine whether they reflect the expenses incurred and whether the utilization rates reflect industry practices.”  Audits will focus on practice expense components, such as the equipment utilization rate.

• Controls over networked medical devices at hospitals. The OIG will examine whether Centers for Medicare and Medicaid Services oversight of hospital security controls over networked medical devices is sufficient to protect the security and privacy of electronic health information. The OIG specifically identifies radiology systems as devices that are integrated with electronic medical records and larger health networks and potentially pose a threat to the security and privacy of personal health information. According to the American College of Radiology, the findings of an OIG audit could result in hospitals imposing additional IT requirements on radiologists and their electronic records systems.

In a report on its Web site, the ACR offered the following advice: "Members who render patient care in the areas listed in the work plan should not expect an immediate knock on their office door from the OIG. However, it could happen. As always, radiologists and their staffs should properly document the medical necessity of and correctly code and bill for their services."

Click here to see the entire 2015 Work Plan.