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Office Of Inspector General 2015 Work Plan

Strategic Management Services, LLC | November 2014

 

Office Of Inspector General 2015 Work Plan

11-04-2014
[CLICK HERE TO DOWNLOAD WORK PLAN] On October 31st, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) issued their fiscal year (FY) 2015 Work Plan (the Plan). The OIG operates through four major divisions: Office of Audit Services (OAS), Office Evaluation and Inspection (OEI), Office of Investigations (OI), and Office of Counsel to the Inspector General (OCIG). The OAS and OEI represent the bulk of the plan by providing information regarding intended areas of work, whereas the OI and OCIG primarily respond to legal issues as they arise. However, the Plan discusses several initiatives that involve these functions as well. The Plan addresses the Fiscal Year that began on October 1st of this year. It is worthy to note that this year, the OIG released the Plan three months earlier than last year, which had a release date of January 31, 2014. This posting will provide a quick look at the Plan.

HHS oversees over 300 different programs, but most of the projects in the Plan focus on the major entities, including the Centers for Medicare and Medicaid Services (CMS); the public health agencies; the Administrations for Children & Families; and the Administration on Aging. Some of the Plan’s undertakings also relate to issues that cut across departmental programs, including the use of federal funds by state and local governments. The Plan for Fiscal Year 2015 summarizes new and ongoing reviews and activities that the OIG plans to pursue with respect to HHS programs and operations during the current fiscal year and beyond. The Plan describes the OIG’s primary objectives and provides its internal identification code for each review as well as the year in which they expect one or more reports to be issued as a result of the review. It is worth noting that some of the projects in the Plan are statutorily required, such as the audit of the department’s financial statements, which is mandated by the Government Management Reform Act. In some cases, reviews are requested by Congress or the Secretary of HHS, but the great majority of the items appearing in the Plan are discretionary to the OIG.

What The Work Plan Is And What It Is Not

It is prudent to keep in mind that the Plan is intended work for FY 2015 as of the date of its release. The following are considerations in reviewing the Plan:

1. It does not restrict the OIG from adjusting their schedule to delay or drop projects, or to include new projects to address issues arising during the year.
2. Many of the projects planned and initiated may not be completed during the year and there are projects in the 2015 Plan that are carried over from the prior year.
3. The OIG may (and often will) engage in audits and evaluations in connection with issues that are not listed in the Plan.
4. The OIG does not provide additional details on jobs to be undertaken or information on the status of jobs contained in its Plan.

The inclusion of an item in the Plan does not necessarily mean that OIG will seek enforcement with regard to that item, or that all interested parties will be contacted by the OIG in connection with a review. The real value of the plan is in knowing that the OIG is telegraphing issues that have cause for concern and desires to learn more about the topic listed. OIG audits and evaluations often result in enforcement and/or policy recommendations to the applicable agency, and thus, the Plan is a good point of reference in considering targeted areas of focus and audit for internal compliance departments.

Accomplishments Reported

• An expected recovery of $4.9 billion, including $4.1 in investigative receivables (of which $1.1 were Medicaid) and $845 million in audit receivables.
• An estimated $15.7 billion in savings as result of actions taken based on prior OIG recommendations.
• Over $5.8 billion in investigative receivables.
• The exclusion of 4,016 individuals and entities from participation in federal healthcare programs.
• The institution of 971 criminal actions against individuals or entities for crimes against HHS programs.
• The institution of 533 civil actions including false claims and unjust-enrichment lawsuits.

Quick Glance At The Work Plan

The Work Plan outlines new and continuing OIG operations and reviews. Most of work plan items reflect continuation of work previously reported in prior plans. New items are denoted by “(New)” after the project title. New projects are followed by the year the project will begin, and a report may be issued in the same year or the following year. Ongoing projects are followed by the year a report is expected to be issued. For each planned review, the OIG provides: (1) an internal identification code; (2) the year in which the OIG expects to issue results; (3) information as to whether the work is a continued or a new focus. The OIG posts all issued reports to its website.

As expected, the OIG will continue include to review entities, including hospitals, nursing homes, hospice, and home health services. Examples of Work Plan items for FY 2015 include:

• New inpatient admission criteria;
• Medicare oversight of provider-based status;
• Duplicate graduate medical education payments;
• Outpatient evaluation and management services billed at the new-patient rate;
• Oversight of hospital privileging;
• Questionable billing patterns for Part B services during nursing home stays;
• Hospice general inpatient care;
• Home health prospective payment system requirements;
• Diagnostic radiology-medical necessity of high-cost tests; and
• Selected independent clinical laboratory billing requirements.

The OIG uses the Plan as part of their policy of transparency. They want everyone to know new areas of current interest to them. They do this so that individuals and entities will be able to review the work plan and use it to compare issues identified by the OIG to their own organization. This will allow time to help everyone “bring their house” in better order. As such, all entities involved in HHS program should examine the OIG Plan and review risk areas related to their areas of operation to permit, where needed, corrective action measures to avoid OIG enforcement actions.

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