Compliance Planning: OIG Switches from Semi-Annual to Monthly Work Plan Updates

When it comes to running a laboratory compliance plan, the semi-annual OIG Work Plan can be a big help to because it enables you to keep track of new enforcement initiatives and respond to emerging fraud and abuse issues quickly and effectively. But you'll no longer be able to count on OIG Work Plans every 6 months. Starting in July, the OIG began updating the Work Plan every month. Here's a look at the new approach and what it means to your own compliance efforts.

Navigating the New OIG Work Plan Website
Under the new regime, the key to staying up to date will be to navigate the OIG Work Plan website, which will now be organized into three categories:

• Recently Added, containing new items for the month;
• Active Work Plan Items, into which the Recently Added items will be shifted after a month and remain until the OIG deems them "complete"; and
• Work Plan Archive, containing Work Plan reports dating back to 1997.

The First New Monthly Updates
Key new enforcement initiatives in the first monthly Work Plan updates of June and July that may affect labs include review of:

• Medicare payments for nonphysician outpatient services provided under the inpatient Prospective Payment System;

• Medicare claims for telehealth services provided at a "distant site," i.e., the practitioner's location, that don't have corresponding claims for the "originating site," i.e., the beneficiary's location; and

• Quality data reported by Accountable Care Organizations that have received earned share savings payments under the Medicare Shared Savings Program to ensure compliance with quality measures data reporting rules.

Takeaway: The need to adjust your lab's fraud and abuse compliance efforts to address new OIG Work Plan enforcement initiatives is nothing new. But from now on, you'll have to assess the need for such adjustments on a monthly rather than semi-annual basis. The good news is that if you don't feel like dealing with the OIG website, you can get regular monthly OIG Work Plan updates from NIR's sister publication, GCA.