OIG Work Plan for 2013 – a first look

OIG 2013 Work Plan

Download the OIG Work Plan

Of the many reports and documents that the federal government releases to the public each year, few are more anticipated in healthcare circles than Health and Human Services (HHS), Office of the Inspector General’s (OIG) annual work plan.  So take note … the OIG Work Plan for 2013 has arrived.

Each year at the beginning of October the most current edition of the OIG Work Plan is released.  It provides insight into the areas of focus that the federal government will address in its auditing for compliance with regulations governing the healthcare industry.

The OIG work plan, whether for 2013 or any other year, has proven itself to be valuable

The OIG has over 1,700 professionals deployed throughout the country, and there’s a reason for that level of a workforce.  Simply put, they pay for themselves.  As a matter of fact, regarding FY 2011, the OIG reported that they had …

  • Anticipated recoveries of $5.2 billion
  • Identified $19.8 billion in savings resulting from legislative, regulatory, and administrative actions
  • Excluded 2,662 individuals and entities from participation in federal health care programs
  • Prompted 723 criminal actions against individuals or entities that were identified to have engaged in crimes against HHS programs
  • Initiated 382 civil actions, which included such things as false claims and unjust-enrichment lawsuits

So it’s to be expected that the OIG work plan for 2013 will be followed up with many more years of profitable undertakings.

What information is contained in the OIG work plan for 2013?

While the details of each year’s plan will vary, the purpose remains constant.  In effect, the OIG Work Plan for 2013 includes the same detail that preceding years did …

  • Brief descriptions of the activities that the OIG plans to either continue with or begin as they relate to over 300 programs administered by HHS programs and operations in fiscal year 2013.
  • A concise description of each of the primary objectives of the items listed in the Work Plan.
  • An anticipated projection of the year in which we should expect any reports to be issued to the public that are as a result of the reviews.
  • Identification of whether the work described by the OIG was already in progress at the start of the fiscal year, or if it will be a review item that’s new at the start of 2013.

And it’s written in a manner that’s easy to understand for industry insiders.  So the work plan is a very useful document that can be used by providers in a manner that helps guide them in their own, internal compliance programs.  Consequently, we recommend to download a PDF of the OIG Work Plan for 2013 and that you review those sections that pertain to you and/or your health related business.

Hospitals are an apparent new focus in the OIG work plan for 2013

The OIG work plan for 2013 covers all corners of the industry.  As a matter of fact, this year’s work plan has 329 items listed for review, 107 of which are to be newly added in 2013, and covering 37 major areas that fall under the jurisdiction of HHS.  However, the OIG Work Plan for 2013 has an obvious emphasis on hospitals.  In all there are 25 items of focus for hospitals, 13 of which are new for 2013.  A few examples of the new items include …

Inpatient Billing for Medicare Beneficiaries

This item will focus on how hospital billing for inpatient stays have changed over time.  Specifically, it will review the period of FY 2008 to FY 2012.  And further more, it will review how billing for inpatient stays in FY 2012 have varied among the different types of hospitals.

 


Diagnosis Related Group Window

Cost cuts are again the focus on this OIG review item.  Basically, the current rules bundle all outpatient services delivered 3 days prior to an inpatient hospital admission.  So the OIG work plan for 2013 is exploring the savings that may be found if those services were delivered within 14 days prior to an inpatient hospital admission instead.

 


Inpatient and Outpatient Payments to Acute Care Hospitals

This one will review Medicare payments to hospitals in an effort to determine compliance with selected billing requirements. Specifically, the OIG will use the results of these reviews to recommend recovery of over-payments and identify providers that routinely submit improper claims.  Be aware that this item of focus will include “data mining” techniques that will determine “risk”.  What’s more, local hospital policy and procedure will be assessed against real-life practice.

Updates to the OIG work plan for 2013 … some options

Once any update report is issued by the OIG that’s relevant to its 2013 Work Plan, it will be published on their website.  One of the easiest ways to keep abreast of these postings is to subscribe to the OIG’s email list.  Email subscribers automatically receive notifications once new reports are posted.

The OIG 2013 Work Plan announced on Twitter

I’d also like to add that for those of you who are a bit more involved on the social web, you may find many benefits from following “OIG at HHS” on Twitter via their @OIGatHHS handle.  There’s probably no more timely reference if you really want to keep you finger on the pulse of the OIG’s Work Plan activities and findings.

And speaking of updates, check back with us as we plan to share more of our review of this year’s OIG Work Plan.

 

When you need proven expertise and performance

Thomas M. Lee, Partner

Mr. Thomas M. Lee has over 35 years of experience in the business of healthcare with special emphasis in operations management, financial analysis, financial forecasting, construction projects, and new program development.

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