On March 17, 2015, the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) published its March 2015 Compendium of Unimplemented Recommendations (Compendium). The Compendium includes the 25 most significant unimplemented recommendations included in OIG recent final reports.

In the Compendium OIG again recommends that the Centers for Medicare & Medicaid Services (CMS) seek legislation that would reduce Medicare hospital outpatient department payment rates to equal the payment rates for ambulatory surgery center-approved procedures. OIG estimates that if its recommendation is implemented, Medicare could save as much as $15 billion over five years and beneficiaries could save about $2 billion in reduced co-payments also over a five-year period.

Among the 24 other recommendations OIG also urges CMS to:

  • (i) seek legislative authority to expand the Diagnosis-Related Group window to include additional days prior to the inpatient admission and other hospital ownership arrangements, such as affiliated hospital groups;
  • (ii) revise its regulations, or if necessary pursue a legislative change, to establish a hospital transfer payment policy for early discharges to hospice care; and
  • (iii) provide States with definitive guidance for calculating the Federal upper payment limit (UPL), which should include using facility-specific UPLs that are based on actual cost report data.

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