2014 OIG Work Plan Summary – Part 1

On January 31, 2014, the Office of the Inspector General (“OIG”) of the Department of Health and Human Services released its annual Work Plan.  The Work Plan is designed to summarize and set forth both new and ongoing reviews and inspections that the OIG is or will undertake.  The Work Plan provides insight into the government’s plans for providers and others in the healthcare industry.

The Work Plan is broken into various sections reflecting the scope of the OIG’s oversight responsibilities.  Specifically the Work Plan addresses:

  • Medicare Part A and Part B – This section includes: hospital; nursing homes; hospices; home health services; medical equipment and suppliers; other providers and suppliers; prescription drugs; Part A and Part B contractors; information technology, protected health information and data accuracy; and other Part A and Part B program management issues.
  • Medicare Part C and Part D
  • Medicaid Program – This section includes: Medicaid prescription drug reviews; home health services and other community-based care; other Medicaid services, equipment and supplies; state management of Medicaid; Medicaid information system controls and security; and Medicaid managed care.
  • CMS-related Legal and Investigative Activities
  • Public Health Reviews – This section includes reviewing the following agencies: Agency for Healthcare Research and Quality; Centers for Disease Control and Prevention; Food and Drug Administration; Health Resources and Services Administrative; Indian Health Service; National Institutes of Health; Substance Abuse and Mental Health Services Administration; other public-health related reviews; and public health legal activities.
  • Human Services Reviews
  • Other HHS-Related Reviews

As the list of subjects demonstrates, the Work Plan is a comprehensive summary of all investigative and other activities that the OIG plans to pursue in the coming year.  Identifying new investigations can help key providers into areas where attention should be given in order to stay ahead of the government.  Additionally, the ongoing work aids providers in keeping existing issues on their radar.

This will be the first post to The Pulse about the OIG’s 2014 Work Plan.  Subsequent posts will highlight particular projects set forth by the OIG broken down by the type of provider affected.  However, the highlights will only cover a small portion of the reviews included.  It is suggested that providers review all areas of the Work Plan that could impact their operations in order to help set their own individual compliance plans for the year.

About Matt Fisher

Matt is the chair of Mirick O'Connell's Health Law Group and a partner in the firm's Business Group. Matt focuses his practice on health law and all areas of corporate transactions. Matt's health law practice includes advising clients with regulatory, fraud, abuse, and compliance issues. With regard to regulatory matters, Matt advises clients to ensure that contracts, agreements and other business arrangements meet both federal and state statutory and regulatory requirements. Matt's regulatory advice focuses on complying with requirements of the Stark Law, Anti-Kickback Statute, fraud and abuse regulations, licensing requirements and HIPAA. Matt also advises clients on compliance policies to develop appropriate monitoring and oversight of operations.
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One Response to 2014 OIG Work Plan Summary – Part 1

  1. Pingback: 2014 OIG Work Plan Summary – Part 2: Physician Reviews | Mirick O'Connell Health Law Blog

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