Every year the Office of Inspector General (OIG) issues a Work Plan outlining its projects for the next fiscal year. The OIG’s fiscal year begins in October, and the Work Plan is usually issued around that time. Publication of the work plan for fiscal year 2014 (which began on October 1, 2013) was delayed to January 2014.
What is the Work Plan?
The OIG Work Plan describes the specific risks the OIG plans to research, audit and target. The Work Plan is divided into categories (e.g. Medicare Parts A and B) and further divided into subcategories (e.g. Nursing Homes, Hospices). Some of this year's Work Plan items are continued from the 2014 Work Plan.
What's in the 2015 Work Plan?
A lot! The 2015 Work Plan is 76 pages long, and addresses OIG projects for Hospitals, Hospices, Home Health, Nursing Homes, Medical Equipment & Supplies, Other Providers (such as physicians and ambulance services), Prescription Drugs, Contractors, Health IT, Medicare Advantage, Part D, and Medicaid.
For example, the OIG plans to look at the following areas in nursing homes:
- Medicare Part A billing
- Questionable patterns for Part B services during nursing home stays
- State agency verification of deficiency corrections
- Program for national background checks for long-term care employees
- Hospitalizations of nursing home residents for manageable and preventable conditions
...and these areas for home health:
- Home health prospective payment requirements
- Employment of individuals with criminal convictions
What's in it for me?
The OIG Work Plan is an extremely valuable tool for the compliance officer. By announcing the areas it will be reviewing, the OIG Work Plan enables providers to conduct audits of these areas and make sure it is addressing them. This is equivalent to a teacher giving students test answers before the test – anyone who doesn’t get an "A" only has lack of effort to blame. You can read the entire Work Plan here. By incorporating applicable Work Plan items into your OIG compliance program, you can make OIG priorities your priorities too.