Exclusion Screening

OIG Work Plan – A Compliance Reminder


Emptech's founder, Jeff Aleixo


Jeffrey Aleixo

OIG work plan doctor holding checklist

Healthcare compliance of every organization should demonstrate its commitment to adherence to the law and ethical standards as well as requirements of the Office of Inspector General of the U. S. Department of Health and Human Services. The aim of this organization is to protect the integrity of federal healthcare programs and their beneficiaries by finding and preventing fraud, waste, and abuse, among other activities. These efforts are presented in the OIG Work Plan that includes different ongoing projects or projects that are planned in the near future as part of the OIG mission.

The Purpose of the OIG Work Plan

The OIG Work Plan defines various projects including OIG audits and evaluations that are planned during a fiscal year and beyond by the OIG’s Office of Audit Services and Office of Evaluation and Inspections. Projects listed in the Work Plan include the Centers for Medicare & Medicaid Services (CMS), public health agencies such as the Centers for Disease Control and Prevention (CDC) and National Institutes of Health (NIH), and human resources agencies such as Administration for Children and Families (ACF) and the Administration on Community Living (ACL). The OIG also plans work related to issues that refer to departmental programs, including State and local governments’ use of Federal funds, as well as the functional areas of the Office of the Secretary of Health & Human Services (HHS). Apart from this, some Work Plan items reflect work that is statutorily required.

In evaluating potential projects to undertake, the OIG considers a number of factors, such as:

  • mandatory requirements for OIG reviews, as required by laws, regulations, or other directives;
  • requests made or concerns raised by Congress, HHS management, or the Office of Management and Budget;
  • top management and performance challenges facing HHS;
  • work performed by other oversight organizations;
  • management’s actions to implement OIG recommendations from previous reviews; and
  • potential for positive impact.
Use this comprehensive guide to ensure a proactive approach to successfully achieving and maintaining healthcare compliance.

Monthly Updates of the Work Plan

In June 2017, the OIG made a change in how its Work Plan is administered. Previously, it was published once a year and contained the specific activities the OIG would undertake in the following 12 months. Now, however, the OIG continuously updates the Work Plan, adds new auditing activities, and removes old items once their review is completed. These adjustments are made throughout the year in order to meet priorities and to anticipate and respond to emerging issues. The list of Active Work Plan Items is searchable by a month of listing, by agency, by title, and by Report number. Healthcare providers can also easily identify projects that have recently been issued, and recent final reports.

Accordingly, a key component of every healthcare compliance program should include monitoring and assessing how items included in the OIG Work Plan may impact the practice and its operations. Monitoring this list, and incorporating some of the issues can significantly improve compliance and help healthcare providers avoid any potential problems.

Learn how to avoid OIG Corporate Integrity Agreement, what steps to take in order to create a voluntary compliance program, and how to prevent penalties for failure to comply.

Highlights of the 2019 OIG Work Plan

In 2019, the OIG has identified a number of specific areas of concern related to different requirements. Some of those key areas are:

  1. Opioid-related issues, including oversight of opioid prescribing and addressing related matters. Physicians who prescribe opioids need to pay attention to oversight activities and make sure to comply with applicable state and federal rules.
  2. When it comes to Medicare billing and documentation compliance, the OIG draws attention to different issues, such as:
  • Medicare payments for critical care that need to be paid in accordance with Medicare requirements;
  • Improper Medicare payments for outpatient cardiac and pulmonary rehabilitation services;
  • Questionable billing rates related to three off-the-shelf orthotic devices;
  • Inappropriate payments for outpatient dialysis services provided to patients diagnosed with end-stage renal disease;
  • Audit and verification of data collected by CMS with respect to post-operative services included in global surgery payments; and
  • Improper payments made to providers that should have been covered under per diem payments made to hospice organizations.
  1. Since they are based on a per-person rather than a per-service basis, the OIG has identified a number of actions to take related to Part C plans.
  2. One of the activities is also a review of Medicare Shared Savings Plan Accountable Care Organization strategies aimed at reducing spending and improving quality.

Ensuring Continued Compliance

Activities aimed at preventing fraud and ensuring patient safety in the healthcare industry continuously evolve. Thus, efforts for creating a culture of compliance have become a necessity. In order to achieve this, healthcare providers need to make compliance plans a priority, understand fraud and abuse risk areas, and manage financial relationships.

Yet, there are many different aspects of compliance in healthcare. Between ever-changing industry standards and federal, state, and local laws and regulations, it can be difficult to remain compliant. This is why healthcare providers should consider outsourcing healthcare compliance activities and start utilizing technology to reduce costs while gaining efficiency. In addition to this, by monitoring the OIG Work Plan, physicians can be proactive and make any necessary changes to ensure continued compliance in certain key risk areas identified by the OIG. As a result, healthcare organizations can monitor the data more accurately and efficiently with reliable technology while staying on top of the areas where the OIG is focusing its investigative and enforcement actions.

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