Have you heard of the OIG’s Work Plan? Effective June 15, The OIG announced that it will update its Work Plan website monthly and provide more timely information. Usually, compliance professionals have been accustomed to receiving annual OIG Work Plans between August and October, and possibly an update once a year on the progress. Let’s take a look at some of the new features and content.
The Work Plan sets forth various projects that the OIG for HHS will address in the year. It includes OIG audits, evaluations, and inspections division. The Work Plan projects under the OIG purview cover across many federal departments including:
- Centers for Medicare and Medicaid Services (CMS),
- Public health agencies such as the Centers for Disease Control and Prevention (CDC)
- National Institutes of Health (NIH) and
- Human resource agencies such as Administration for Children and Facilities (ACF) and the Administration on Aging (AoA).
The Work Plan also relates to issues that cut across departmental programs, including State and local governments’ use of Federal funds, as well as the functional areas of the Office of Secretary of Health and Human Services (HHS).
How the OIG approaches its Work Plan
The OIG assesses risks it deems important and relevant to the mission of protecting the integrity of HHS programs and the health and welfare of the people it serves under those programs. The Work Plan identifies those programs and operations that are most in need of attention and sets priorities for allocation of resources. When evaluating potential projects to pursue the OIG utilizes the following factors:
- Mandatory requirements for OIG reviews, as set forth in 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 (e.g., GAO)
- Management’s actions to implement OIG recommendations from previous reviews
- Potential for positive impact
Further, the OIG Work Plan also includes a number of legal and investigative activities such as those pertaining to investigating fraud, waste and abuse, facilitating compliance in the healthcare industry, and excluding “bad actors” from participation in Federal healthcare programs (OIG List of Excluded Individuals and Entities).
The OIG recognizes that organizations plan according to their stated Work Plan and that by making their reports monthly updates, it is more dynamic and ensures that providers are in sync with the OIG efforts to curtail fraud and abuse. This allows companies to be more “closely aligned with the work planning process” according to the OIG site.
What to Expect
The monthly update includes the addition of newly initiated Work Plan items and the removal of completed items. Recently, published reports can be found at the OIG’s What’s New page. Is it time to update your Work Plan planning to check monthly for new items and closed out items that the OIG has or is addressing? The new schedule and outline is another example of the OIG working towards continued transparency and being a partner in helping the industry plan and fight fraud, waste, and abuse. Be sure to add this page to your monthly review of news and resources from the OIG.
Written by Michael Rosen, ESQ
Michael brings over 20 years of experience founding and leading risk mitigation businesses, receiving numerous accolades such as: Inc Magazine’s Inc 500 Award and Nashville Chamber of Commerce Small Business of the Year.