In November 2014, the American Hospital Association sent a letter to the OIG urging it to stop conducting hospital compliance reviews and extrapolating the findings of audits citing numerous legal problems with the extrapolation method.
In its response, the OIG rejected the AHA’s claim that its extrapolation methods are flawed and said, “Determining the overpayment through sampling and extrapolation, rather than reviewing each claim, is both economical and in the best interest of the provider and the government. OIG uses a conservative method under which overpayment estimates will almost always be lower than the estimates that would result from reviewing every claim.”
The OIG said its hospital compliance reviews serve an important function and that it hopes hospitals’ compliance departments will use the review results “to reduce the number of billing errors in the future and to otherwise strengthen the cultures of compliance at their facilities.”
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