OIG Work Plan – A Forecast of Federal Healthcare Fraud and Abuse Risk Areas

OIG Work PlanWhen people in healthcare talk about “the OIG”, they mean Office of Inspector General of the U.S. Department of Health & Human Services. The OIG’s mission is to protect the integrity of Federal Health and Human Services programs by using a nationwide network of audits, investigations, and evaluations to protect the health and welfare of the people served by those programs. Health and Human Services Programs include Medicare, Medicaid, Children’s Health Insurance Program (CHIP).

To handle these audits, investigations, and evaluations efficiently, the OIG identifies those areas most in need of attention and sets priorities for the sequence and proportion of resources to be allocated. This is called the OIG Work Plan. The OIG Work Plan sets forth various projects including OIG audits and evaluations underway or planned to be addressed by OIG’s Office of Audit Services and Office of Evaluation and Inspections.

The OIG Work Plan is updated monthly and available online for the public to view. Recent additions to the OIG Work Plan objectives include, but are not limited to:

  • a review of Post-Operative Services Provided in the Global Surgery Period (July 2018);
  • a review of Medicare Part B outpatient cardiac and pulmonary rehabilitation services (May, 2018);
  • an audit of prescription opioid drug abuse and misuse prevention and prescription drug monitoring programs (June 2018);
  • an evaluation of Medicare Part D Denials (June 2018);
  • a mandatory review of Medicare payments for clinical diagnostic laboratory tests (May 2018);
  • an audit of Home Health claims for services with between 5 and 10 skilled visits (June 2018); and
  • a review of Medicare payments made outside of the hospice benefit (June 2018).

As you can see, the OIG Work Plan is designed to evaluate every aspect of health care that interacts with a Health and Human Services program.  When people inquire as to where the Federal government is looking for its next big crackdown, the OIG Work Plan is a crucial part of the answer.

Oftentimes, healthcare providers have no idea where to start with incorporating compliance measures into their practice. The OIG Work Plan is a great place to begin. The Federal government is telling you exactly which practices it is looking at for potential abuses! If you run a cardiology practice, and you know that, as of May 2018, the OIG was reviewing Medicare Part B outpatient cardiac and pulmonary rehabilitation services, maybe it is also time for your practice to review its charts and billing for those services to ensure that all services are documented and billed appropriately.

Moreover, when it comes time to review your compliance program (you do this at least annually, right?), it is a compliance best practice to review the OIG Work Plan for the last 12 months in order to identify any areas of potential risk within your business and review those going forward. Compliance is an evolving concern, and you can use the OIG Work Plan to help your compliance program to be as effective as possible.

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