OIG 2014 Work Plan: Continued Imaging Compliance Focus

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adrienneP.Toutant HeadshotBy Adrienne Dresevic, Esq. and Phillip B. Toutant, Esq. 

On January 31, 2014, the OIG released its Fiscal Year 2014 Work Plan. The Work Plan details areas it intends to focus on in the coming year as it continues to police the healthcare system for fraud and abuse. While the Work Plan encompasses all healthcare providers within the OIG’s purview, it does focus on some areas that are of specific concern for providers/suppliers of imaging services. Amongst others, the OIG Work Plan identifies the following areas that the agency “plans to pursue” in 2014 and beyond:

Diagnostic Radiology – Medical Necessity of High-Cost Tests

The OIG plans to continue its review of Medicare payments to assess medical necessity of “high-cost diagnostic radiology tests.” The agency is also planning to continue conducting surveys to determine whether there has been increased utilization for such tests. The OIG now anticipates issuing a report on its findings in 2015.

Imaging Services – Payments for Practice Expenses

The agency will continue its review of Medicare Part B payments and make a determination regarding whether payments made accurately reflect practice expenses incurred (eg, expenses for office rent, wages and equipment), as well as whether respective utilization rates are consistent with industry practices. For “certain” (unspecified) imaging services, the OIG will focus on practice expense components, including equipment utilization rates. A report on the OIG’s findings is expected in 2014.

Supplier Compliance with Transportation/Setup Fee Requirements for Portable X-Ray Equipment

Due to the OIG’s findings of improper Medicare payments for mobile x-ray transportation (eg, payments for multiple trips to nursing facilities in one day), as well as mobile x-ray services being improperly ordered by non-physicians, Medicare payments for transportation and setup of mobile x-ray equipment are a new area of OIG review. Specifically, the agency is planning on determining whether payments were made correctly, whether payments were supported by documentation, whether the technologists who performed the services were appropriately qualified, and whether the services were ordered by a physician. A report on the OIG’s findings is expected in 2015.


As compliance efforts are reviewed, providers and suppliers should be mindful of these and other issues set forth in the OIG’s work plan. The full text of the OIG’s Fiscal Year 2014 Work Plan can be accessed here.

Adrienne Dresevic, Esq. graduated Magna Cum Laude from Wayne State University Law School. Practicing healthcare law, she concentrates in Stark and fraud/abuse, representing various diagnostic imaging providers, eg, IDTFs, mobile leasing entities, and radiology and multi-specialty group practices.

Phillip B. Toutant, Esq. is a graduate of Michigan State University and Wayne State University Law School. Practicing healthcare law, he concentrates on litigation of contract and other healthcare disputes, False Claims Act defense and licensing matters.

The authors are members of The Health Law Partners, P.C. and may be reached at (248) 996-8510 or (212) 734-0128, or at www.thehlp.com.

For more regulatory news, visit www.ahraonline.org/news.

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