Physician Practice Compliance Planning for 2019: OIG Work Plan Activities

Compliance Today February 2019

Gary W. Herschman and Victoria Vaskov Sheridan, Members of the Firm, and John D. Barry, Associate, in the Health Care & Life Sciences practice, in the firm’s Newark office, co-authored an article in Compliance Today, titled “Physician Practice Compliance Planning for 2019: OIG Work Plan Activities.”

Following is an excerpt (see below to download the full version in PDF format):

The Office of Inspector General of the United States Department of Health and Human Services (the OIG) protects the integrity of federal healthcare programs and their beneficiaries by, among other activities, detecting and preventing fraud, waste, and abuse. These efforts are reflected in a Work Plan that identifies various projects that are underway or that the OIG plans to address in the near future in furtherance of its mission. As a result, a key component of every physician practice compliance program should include monitoring and assessing how items included in the OIG’s Work Plan may impact the practice and its operations.

Looking ahead

By monitoring the Work Plan, a physician practice can be proactive and make any necessary changes to ensure continued compliance in certain key risk areas identified by the OIG. Looking ahead to 2019, physicians and physician groups should be aware of the following Work Plan items. …

Monitor the OIG Work Plan closely

Beginning in June of 2017, the OIG made a major change in how its Work Plan is administered. Previously, the OIG published a Work Plan once a year, which contained the specific activities the OIG would undertake in the following 12 months. For more than a year now, the OIG has been continuously updating the Work Plan, adding new audit activities as they are identified and removing old items when he OIG has completed its review. As a result of this new format, it is prudent for providers to routinely monitor the OIG Work Plan website to identify whether any newly added items may be of particular importance to their practice.