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What is the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) Work Plan and why is it important?

The OIG Work Plan sets forth various projects including OIG audits and evaluations that are in progress or planned to be addressed by the OIG’s Office of Audit Services and Office of Evaluation and Inspections. These projects in the Work Plan include CMS, Centers for Disease Control and Prevention (CDC), and the National Institutes of Health (NIH), among others. OIG updates their Work Plan on their website1 monthly to ensure alignment with their work planning process. It is important for providers and Compliance Officers to frequently review the OIG Work Plan focus areas in order to make any necessary internal audit practices to ensure compliance in areas of vulnerability.

In January 2021, HHS OIG announced recent updates to their Work Plan2. Below is a summary of the January 2021 updates below:

Preventing Fraud, Waste, and Abuse: Orthotic Braces:

  • OIG reports that in their prior work, they identified inappropriate payments for orthotic braces due to lack of medical necessity, documentation was not in accordance with Medicare regulations, or was fraudulent.  OIG plans to compile the results of their audits, evaluations, and investigations of orthotic braces paid by Medicare. They also intend to analyze data for trends in payment, compliance, and fraud vulnerabilities, and provide recommendations.

Medicare Part D Payments During Covered Part A SNF Stay:

  • OIG plans to determine whether Medicare Part D paid for drugs that should have been paid under the consolidated Medicare Part A payment.

Background Checks for Nursing Home Employees

  • OIG reports that in their prior work, they identified that not all States complied with the National Background Check Program for Long-Term Care Providers. OIG plans to determine whether Medicaid beneficiaries in nursing homes in certain states were safeguarded from caregivers with a criminal history of abuse, neglect, exploitation, mistreatment of residents, or misappropriation of resident property.

Audits of Medicare Part B Telehealth Services During the COVID-19 Public Health Emergency

  • OIG will conduct a series of audits of Medicare Part B telehealth services in two phases to determine whether Medicare requirements are met.  The first phase will focus on early assessments of whether services such as evaluation and management, opioid use, end-state renal disease, and psychotherapy met Medicare requirements.  The second phase includes additional audits  related to distant and originating site locations, virtual check-ins, electronic visits, remote patient monitoring, use of telehealth technology, and annual wellness visits. The update does not specify setting they will be focusing on.

Gina Elkins, Director of Compliance and Regulatory Strategy 

Sources:

1. OIG Work Plan Webpage

2. OIG Work Plan Recently Added Page