OIG Switches from Semi-Annual to Monthly Work Plan Strategy

New OIG Work Plans every six months are a thing of the past. In June, the agency announced plans to update its Work Plan website monthly. The self-proclaimed “dynamic,” web-based strategy is intended to “enhance transparency” of OIG’s enforcement efforts and make it easier for labs and other providers to “respond to emerging [fraud and abuse] issues” more effectively.

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.