In a devilish twist, the OIG decided to usher in Halloween with a treat of their own, the 2015 OIG work plan. The issuance of this plan comes a mere eight months after the 2014 OIG work plan, whose publication was delayed a full four months. This year’s work plan, at a mere 90 pages, is about 10% less than its more hefty 2014 version. But, don’t let that fool you-it’s still full of information that should be of great interest and importance to health care providers.
OIG likes to call their investigative and enforcement initiatives “projects”-sounds less threatening don’t you think? At any rate, the 2015 OIG work plan outlines a total of 189 projects spread over seven major categories. It should be noted that this is down from the 209 projects that filled the 2014 work plan. Of those 189 projects this year, there are only 19 new initiatives. The remaining 176 projects are carried over from prior years. Interestingly, the 2014 work plan included 61 new projects, so it looks like the 2015 work plan will place a greater emphasis on initiatives that are already familiar to those providers who have been paying attention in years past. If you’re interested in viewing a more detailed summary of the projects, check out our OIG 2015 Work Plan Overview.
The 2015 OIG Work Plan includes some impressive figures…
Now for those of you out there that may be thinking that the OIG is running out of steam on this investigative and enforcement kick, take a look at these rather impressive (depending on which side of the desk you’re sitting) statistics for FY 2014:
- Exclusions of 4,017 individuals and entities from participation in Federal health care programs
- 971 criminal actions against individuals or entities engaged in crimes against HHS programs
- 533 civil actions which includes false claims lawsuits, CMP settlements and administrative recoveries
If that wasn’t enough, the OIG reported expected FY 2014 recoveries of $4.9 BILLION as well as identifying $15.7 BILLION in estimated savings based on prior period legislative, regulatory and administrative actions supported by OIG recommendations. Is it any wonder that the OIG continues to actively and aggressively work this program?
The figures for the number of excluded individuals and entities as well as the number of criminal actions are up slightly from last year. It’s a sobering commentary that despite the issuance of these work plans annually by the OIG and the call to action for active and dynamic compliance programs, providers are still running afoul of the laws and regulations.
Your compliance program and the 2015 OIG Work Plan…a happy couple???
Now is a great time to give your compliance program an annual check up. And while you’re at it, why not take a look at the 2015 OIG work plan-for those that haven’t read it before, no need to fear it. The document lends itself to a fairly easy review as projects are grouped together by category. Does your compliance program address those OIG investigative and enforcement initiatives? If it does, congratulations and if not, isn’t it better that you identify it and correct it?
Stay tuned, over the course of the next few days, we’ll be posting additional blogs which cover more in depth the components of the 2015 OIG work plan.