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October 2012


A Polsinelli Shughart Update:

Highlights and Strategies to Prepare for the Implementation of the HHS OIG 2013 Work Plan


The U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) released its FY 2013 Work Plan recently which outlines the new and ongoing issues and activities that the OIG plans to pursue with respect to HHS programs and operations. The Work Plan highlights special areas of interest to the OIG, which often translate into increased compliance risks for providers.

[Click here for a link to the OIG's 2013 Work Plan.]

Areas of Interest to all Providers

As a general matter, the 2013 OIG work plan contains initiatives focused on identifying areas of waste and abuse while attempting to promote quality and safety.  Additionally, there are multiple provisions using data mining to accomplish these goals.  There is a particular emphasis on identifying waste, such as duplicative and excessive payments, from existing payment policies for all providers.  Attention is paid to the disposition of patients and the payment policies associated with transitions into and out of various care settings. 

Additionally, there are many new areas of focus related to prescription medications and medical equipment.  Issues and initiatives regarding drug shortages, off-label usage and antipsychotic medication in the young and elderly are prominent; as are concerns related to proper billing and payments.  However, in the area of prescription drugs, the OIG Work Plan emphasizes patient safety and quality of care over payments an billing policies this year. 

The work-plan also focuses the OIG’s attention towards monitoring Medicare Contractors and State Agencies charged with identifying overpayments, recovering moneys for CMS as well as prosecuting abuse to ensure they are effective.  There is no suggestion that the OIG will be looking to scale-back or limit the scope and authority of states' or contractors’ roles this year.

Although these trends are of interest to all providers, a more detailed summary of the new issues and continuing trends applicable to specific providers is provided below:

What You Should Do Now

We recommend that our clients take the following actions:

  1. Review these highlighted topics and determine which are applicable to your organization

  2. Review internal auditing and monitoring processes, such as compliance reviews, to determine if the identified areas of interest are being properly reviewed

  3. Initiate or update the review process for these identified areas of interest to ensure that they are being properly maintained

For More Information

If you have questions regarding this regulatory update or any other issues, please contact:

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