Since its establishment in 1976, the Office of Inspector General (OIG) has been at the forefront of the nation’s efforts to fight waste, fraud, and abuse in Medicare, Medicaid, and more than 100 other Health & Human Services (HHS) programs. Collectively, the costs of these federal health and human services programs exceed $1 trillion each year. This government office annually determines a Work Plan that outlines its methods of combating inefficiencies across all HHS programs. Learn more about the background of the OIG Work Plan and key takeaways from its latest version.
- What is the OIG Work Plan?
- How Often is the OIG Work Plan Updated?
- Why Does the OIG Work Plan Matter for Medical Practices?
- Key Takeaways from the 2021 OIG Work Plan
- Need Help Ensuring Your Revenue Cycle Efforts Aren't Subject to OIG Scrutiny?
What is the OIG Work Plan?
In recognizing that fraud, waste, and abuse are huge problems across the healthcare space, the Office of the Inspector General (OIG) publishes a Work Plan outlining the ways it plans to combat those issues. Given that the OIG is the organization charged with preventing and investigating financial mismanagement by providers, this information really should be required reading for physicians and medical practice managers – if only so they know what concerns to watch out for in medical billing and coding.
Naturally though, few healthcare stakeholders take the time to read the Work Plan in order to use it to mitigate their risk factors. We encourage you to be one of the few; the OIG website is easy to navigate and provides a table of information rather than a massive block of text. The full Work Plan lists out the OIG’s Medicare and Medicaid review initiatives and intended areas of evaluation, most of which apply primarily to hospitals and nursing homes.
OIG carries out its mission to protect the integrity of HHS programs and the health and welfare of the people served by those programs through a nationwide network of audits, investigations, and evaluations, as well as outreach, compliance, and educational activities.
How Often is the OIG Work Plan Updated?
The OIG Work Plan was formerly updated and published just once or twice a year; since June 15, 2017, the Work Plan is actively updated at least once a month to reflect the office’s active endeavors and to enhance public transparency. The OIG’s work planning process is dynamic, so adjustments are made throughout the year to meet priorities and to anticipate and respond to emerging issues with the resources available. This web-based Work Plan will evolve as OIG continues to pursue complete, accurate, and timely public updates regarding its planned, ongoing, and published work.
Why Does the OIG Work Plan Matter for Medical Practices?
The OIG Work Plan sets forth various projects including OIG audits and evaluations that are underway or planned to be addressed during the fiscal year and beyond by OIG's Office of Audit Services and Office of Evaluation and Inspections. Projects listed in the Work Plan span the Department and include the Centers for Medicare & Medicaid Services (CMS), human resources agencies such as Administration for Children and Families (ACF) and the Administration on Community Living (ACL), and more.
The Work Plan’s effects don’t stop at the last agency name - the procedures and regulations outlined in the Plan also impact your medical practice! Your medical practice will be impacted if you’ve ever billed Medicare or Medicaid, or if you’re contracted with a nursing facility. As the OIG’s main goal is always to eliminate waste, fraud, and abuse in hundreds of areas, you can consider it a government guidebook for protecting your practice against these negative qualities, too.
Key Takeaways from the 2021 OIG Work Plan
With so many additions to the Work Plan happening every few weeks, it can seem intimidating going through the OIG website! Here are some of their latest updates that might most help you and your medical practice:
Auditing of Telehealth Services
In October 2020, CMS announced its plan to begin auditing Medicare Telehealth Services. CMS has implemented a number of waivers and flexibilities that allowed Medicare beneficiaries to access telehealth services; as such, Medicare Part B and C data will be reviewed for program integrity risks associated with telehealth services during the pandemic. The OIG will analyze provider billing patterns, and focus on selected states’ use of telehealth in behavioral health services. Furthermore, the OIG will also be reviewing Medicaid Telehealth for oversight of state agencies and waivers that occurred during the COVID-19 pandemic.
Reviews of COVID-19 Add-on Testing and Laboratory Billing
In June 2020, the OIG added an item related to laboratory add-on tests to confirm or rule out a diagnosis other than COVID-19, as well as the ordering provider. These add-on tests in conjunction with COVID-19 testing, such as respiratory pathogen panel (RPP) tests, allergy tests, or genetics tests will be reviewed for medical necessity and appropriateness.
Two-Midnight Rule for Inpatient Admissions
In November 2020, the OIG announced a revised plan to begin auditing short-stay claims in 2021 related to the implementation of the Two-Midnight Rule in Fiscal Year 2014. Under this rule, it is generally considered inappropriate to receive payment for stays not expected to span at least two midnights.
Other key items to look at for 2021 include waiving or reducing co-payments under telehealth policy, infection control items related to guidance in some areas, Medicaid provider enrollment, COVID inpatient discharges, cybersecurity review of HHS, review of CARES Act, Provider Relief Funds, emergency preparedness, and other long-standing OIG audit areas.
Need Help Ensuring Your Revenue Cycle Efforts Aren't Subject to OIG Scrutiny?
No matter the time an organization reviews the OIG Work Plan, this resource is important in creating an annual audit plan and educating leadership on ongoing OIG activities. In addition to this extra research, your medical practice can be prepared for any emerging billing audits or regulations by using a third-party medical billing service!
Outsourcing your medical billing process over to a third party also frees up time for office staff to focus on providing the best service and care possible. Instead of spending hours on the phones trying to collect outstanding payments, a medical billing company can focus on expanding the practice’s patient base and improving the practice’s healthcare experience to better retain the patients it already has.
NCG Medical has four decades of experience with handling coding and billing issues for a variety of healthcare practices. We understand that each practice is unique and requires a customized solution that aligns with its long-term goals. That’s why we work closely with our clients to help them set up the medical billing services and solutions that meet their specific needs and allows them to deliver the best care possible. To find out what we can do for your practice, contact our team today for a consultation.