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The Health and Human Services Office of Inspector General (OIG) last week released the findings of its July 30 roundtable aimed at coming up with solutions for the most onerous aspects that corporate integrity agreements (CIAs) are placing on hospitals and other health care providers. One of the areas that now looms large is site visits. "The thing that is terrifying for most people is employee interviews," says Jamie Whitten, a health care attorney with Jones Day in Washington, DC. "It can be an overwhelming experience."
According to an OIG program analyst, there were 18 sites visits in FY 2000 and approximately 30 site visits in FY 2001. In addition, he says, the Centers for Medicare and Medicaid Services (CMS) now has 25 program safeguard contractors engaged in this process. The OIG also has signed an agreement with Tricenturion in Columbia, SC, to conduct billing reviews and verification audits to support OIG compliance monitoring efforts in the next contract year, Whitten reports.
During on-site visits, the OIG now meets with compliance staff, the board of directors, and employees to review compliance systems and test audit procedures and claims review. But Whitten maintains that it is a misconception that agents participate in site visits. Typically, the on-site review team is made up of compliance unit staff members and sometimes a CMS representative.
He notes that recent OIG Q&A on-site visits indicate that health care providers can have somebody present during the interview, but the OIG requests that it not be the compliance officer because questions asked during the interview might specifically relate to the compliance officer’s performance.
Regardless of how that is handled, Whitten says, hospitals must approach these interviews very carefully. "They should know in advance who is going to interview and prep them," he warns. "They should be handled just like any other government investigation."
The OIG report is available at www.hhs.gov.