October 16, 2019

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October 14, 2019

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2014 Work Plan for Skilled Nursing Facilities (SNFs), Hospice & Home Health Services

If you are a physician and want to know the specific initiatives in the OIG’s 2014 Work Plan applicable to you, check out the post from earlier this week. Today, we will be examining the OIG’s enforcement priorities for skilled nursing facilities (“SNF”), hospice, and home health services.


Based upon prior OIG audits and research, the OIG found that SNFs were responsible for a large number of billing errors and that SNFs increasingly bill for the highest level of therapy even though beneficiary characteristics remain largely unchanged. The OIG will review SNF’s billing practices and describe the variations in billing for selected years.

As part of a continued initiative, OIG will still focus on the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting.


The OIG will examine the extent to which hospices serve Medicare beneficiaries, who reside in assisted living facilities (“ALFs”), by scrutinizing the length of stay, level of care, and common terminal illnesses of beneficiaries.

In addition, the OIG plans to review hospice inpatient care for appropriateness of claims, election statements, and level of hospice care.

Home health services

The 2014 Work Plan did not announce any new initiatives related to home health services, but the OIG will continue to review various aspects of the home health prospective payment system, including Medicare’s documentation requirements. In addition, the OIG will continue to monitor the extent to which home health agencies are complying with state requirements for conducting criminal background checks on applicants and employees.

The OIG Work Plan is a great source of information and good indicator of where the OIG will devote its resources. When preparing internal audits and identifying compliance priorities, entities should ensure key risk areas identified by the OIG are part of their internal review. 

© 2019 by McBrayer, McGinnis, Leslie & Kirkland, PLLC. All rights reserved.


About this Author

Emily M. Hord, Health Care Attorney, McBrayer Law Firm

Emily M. Hord is an Associate of McBrayer, McGinnis, Leslie & Kirkland, PLLC. Ms. Hord concentrates her practice in healthcare law and is located in the firm’s Lexington office. Ms. Hord has experience in a variety of health law issues. She has represented hospitals and healthcare networks, physicians and other medical professionals, nursing homes, and private physician practices. She provides services in the following areas: regulatory and statutory compliance, Certificate of Need and licensing, professional license defense, employment contracts for medical professionals, HIPAA...