The U.S. Department of Health and Human Services (HHS) Office of Inspector General’s (OIG) Work Plan is one of the most valuable resources available for healthcare compliance professionals. The OIG’s work planning process is dynamic and adjustments are made throughout the year to meet priorities and to anticipate and respond to emerging issues with the resources available. Previously, the OIG updated its public-facing Work Plan once or twice a year, but their update cadence has changed as of last month. In order to enhance transparency around the agency’s continuous work planning efforts, effective June 15, 2017, OIG will now update its Work Plan website on a monthly schedule.

Here’s what you need to know about the new monthly update format.

Navigating the New Monthly Work Plan Format

The OIG updates their dynamic, web-based Work Plan monthly to ensure that it more closely aligns with the work planning process, according to their website. When reviewing each monthly update, keep the following in mind:

• Newly Initiated Work Plan Items: These can be found on the OIG’s Recently Added Items page. This page lists the date the items were updated, the agency making the update, the title of the item, and a link to more details about the item.
• Recently Published Reports: Check the OIG’s What’s New page for these. The agency has updated the Work Plan around the middle of each month since the new monthly schedule went into effect.
• Completed Work Plan Items: Note that these items will removed as they are completed. While there does not appear to be an area that lists items that have been removed, you can access the Active Work Plan Items page to view those that remain on the plan.

The new monthly format is meant to provide more accurate and timely information to the public. “This web-based Work Plan will evolve as OIG continues to pursue complete, accurate, and timely public updates regarding our planned, ongoing, and published work,” their website states.

Recently Added Work Plan Items in July 2017

As part of their most recent update from July 17, 2017, the OIG added 14 items from the Centers for Medicare & Medicaid Services (CMS) to their dynamic web-based Work Plan. Here’s an overview of a few of the items added in this update:

• High-Risk, Error-Prone Home Health Agency (HHA) Providers Using HHA Historical Data: Using Data from CMS’s Comprehensive Error Rate Testing (CERT) program, the OIG will identify the common characteristics of “at risk” HHA providers that could be used to target pre- and post-payment review of claims.
• Nationwide Medicare Electronic Health Record (EHR) Incentive Payments to Hospitals: Previous OIG reviews of Medicaid EHR incentive payments found that State agencies overpaid hospitals by $66.7 million, resulting from inaccuracies in the hospitals’ calculations of total incentive payments. The OIG will review the hospitals’ incentive payment calculations to identify potential overpayments that the hospitals would have received as a result of the inaccuracies.
• Review of Medicare Payments for Telehealth Services: Medicare pays for telehealth services provided through live, interactive videoconferencing between a beneficiary located at a rural originating site and a practitioner located at a distant site. An eligible originating site must be the practitioner’s office or a specified medical facility, not a beneficiary’s home or office. The OIG will review Medicare claims paid for telehealth services provided at distant sites that do not have corresponding claims from originating sites to determine whether those services met Medicare requirements.

For a full list of the items added, visit the OIG’s Recently Added Items page.

What do you think about the OIG’s new Work Plan update schedule? Please share your thoughts in the comments section below.