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2015 CMS and OIG Updates


  • CMS released its 2015 National Impact Assessment of the Centers for Medicare and Medicaid Services (CMS) Quality Measures Report. This assessment is required by the Affordable Care Act to assess quality measures and the development of National Quality Strategy (NQS).
  • CMS and the American Medical Association released additional guidance and support for the implementation of ICD-10, which is set to go into effect on October 1, 2015. CMS is also allowing some assistance and flexibility for providers to get claims paid.
  • CMS has finalized the rule for Medicare Shared Savings Program. This rule includes:
    • Increased flexibility
    • Increased focus on primary care services
    • Streamlining of data sharing between CMS and ACOs
    • A new track, Track 3, which includes higher rates of shared savings and a waiver of the 3-day Skilled Nursing Facility Rule for ACO beneficiaries in Track 3.
  • Proposed Update to the Physician Fee Schedule. This represents the first update since the repeal of the Sustainable Growth Rate (SGR), and includes:
    • Merit-based Incentives Payment System (MIPS)
    • Updates to payment policies, including systems created to measure quality
  • CMS Proposes Loosening up the Two-Midnight Rule
    • Would allow for increased physician discretion in admitting patients for short stays
    • RACs no longer to review these cases, will be moved to the quality review organizations
  • Open Payments Data Released from 2014
    • $6.49 billion paid from Industry to physician and teaching hospitals
  • For additional information on CMS initiatives and activities, see http://www.cms.gov.


  • OIG anticipates $1.8 billion in recoveries for the first half of 2015.
  • OIG released its mid-year Work Plan updates. Key additions include:
    • Reviewing billing trends for Part D drugs, particularly Opioids subject to frequent abuse
    • Review of clinical lab payments
    • Analysis of financial arrangements reported under the Open Payments System
  • OIG released new guidance for Health Care Boards of Directors.
    • The emphasis was on information and reporting systems to provide adequate information to the Boards about Compliance issues.
  • For additional information on OIG guidance and initiatives, see http://oig.hhs.gov.

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