“We recommend our clients dedicate time to thoroughly understand the OIG Work Plan—it’s a helpful tool to identify corporate compliance risk areas and it can also assist you with your compliance planning, policies, and activities,” urges Trey Sturtevant, a health care reimbursement principal with LarsonAllen.

Over the past several years, the OIG has allocated about 80 percent of its resources to reviews and investigations of Medicare and Medicaid programs and touches virtually all segments of the health care industry.

Work plan components
The OIG Work Plan is organized by program type (i.e., Medicare, Medicaid) and then by provider type (i.e., Medicare hospitals, Medicare physicians, Medicaid mental health services). The following list includes some of the OIG focus areas in the coming year:

• Hospital capital payments
• Medicare dependent hospital program
• Inpatient Prospective Payment System wage indices
• Critical Access Hospitals
• Long-term care hospital payments for interrupted stays
• Provider bad debts
• Accuracy of coding and claims for Medicare home health resource groups
• Oversight of Medicare skilled nursing facility cost reports
• Accuracy of coding for Medicare skilled nursing facility RUG claims
• Medicare hospice care for nursing home residents
• Physician coding of place of service related to ambulatory surgical centers and hospital outpatient departments
• Evaluation and management services during global surgery periods
• Medicare “incident to” services
• State Medicaid payments for hospital outliers
• Hospital eligibility for disproportionate share hospital payments
• Billing for Medicaid nursing home patients transferred to hospitals

In addition, the work plan also identifies projects and investigations associated with medical equipment and supplies, Medicare Advantage, Medicare Part D administration, and several other issues related to the Centers for Medicare & Medicaid (CMS).