Current HHS Inspector General Work Plan

The Office of Inspector General at the Department of Health and Human Services has released its annual work plan.  The OIG is responsible for ensuring that federal health programs like Medicare, Medicaid and CHIPS are well-managed and not subject to fraud and abuse.  The work plan sets forth priority areas for reviews in the coming year or two.  (OIG Work Plan)

As might be expected, much of OIG’s effort is focused on payments to providers and suppliers, since that is where most of the Medicare and Medicaid money goes.  But it also looks at contractor performance, Medicare Advantage plan issues and a number of public health programs.  Home health agencies, nursing homes and hospices get a fair amount of attention, to some extent because of a perceived history of problems.  Imaging also is a priority and independent diagnostic facilities, particularly in areas where they are geographically concentrated.   Prescription drug reimbursement, particularly calculations of WAMP, ASP and AMP and rebates, continues to receive a lot of OIG attention.

Looking at the work plan can give private insurers a sense of where at least the OIG believes there may be fraud and abuse or other issues.  It can also be a leading indicator of legislative or regulatory changes, as OIG investigations in the past have often led to new payment methods or other changes to reimbursement and eligibility for payment.