OIG 2008 Work Plan - Physicians

Annually in October, the OIG releases its Work Plan for the coming Fiscal Year.  The HHS Office of Inspector General Work Plan previews OIG projects that are scheduled in the upcoming year for each of the major entities within the Department of Health and Human Services:

- Centers for Medicare and Medicaid Services

- Public Health Service Agencies

- Administrations for Children, Family, and Aging         

Information is also provided on projects related to issues that cut across departmental programs, including state and local government use of Federal funds, as well as the functional areas of the Office of the Secretary. Some of the projects described in the Work Plan are statutorily required, such as the audit of the department’s financial statements, which is mandated by the Government Management Reform Act.  The Work Plan can serve as an invaluable guide for professionals and organizations to identify the targets of OIG scrutiny and enforcement activity. The 2008 Work Plan covers the full spectrum of healthcare and human services, from medical necessity and coding issues to clinical trials and care provided in nursing homes.  Below are hot topics being targeted in the 2008 OIG Workplan:

Nursing and Allied Health Education Payments
The OIG will review payments for provider-operated nursing and allied health (NAH) education programs. The Medicare program makes payments to hospitals for provider-operated NAH programs on a reasonable-cost basis in accordance with Federal regulations at 42 CFR § 413.85.  They will determine whether payments to providers for these costs were appropriate.

Payments to Organ Procurement Organizations
The OIG will review Medicare payments made to organ procurement organizations (OPO). An OPO coordinates the retrieval, preservation, and transportation of organs for transplant and maintains a system to allocate available organs to prospective recipients. Medicare reimburses OPOs under 42 CFR § 413.200 according to a cost basis method set out at 42 CFR § 413.24. They will determine whether payments made to OPOs are correct and supported.

Oversight of the Joint Commission Hospital Accreditation Process
The OIG will review CMS’s policies and procedures regarding the Joint Commission hospital accreditation process. Sections 1861(e) and 1865(a)) of the Social Security Act and the regulations at 42 CFR 488.5 allow institutions accredited as hospitals by the Joint Commission to be deemed to meet the Medicare  conditions of Participation for Hospitals. The Joint Commission accredits about 80 percent of the Nation’s hospitals that participate in the Medicare program. In 2004, the Joint Commission revamped its hospital accreditation process, requiring hospitals to evaluate themselves, typically in the middle of the hospital’s 18-month accreditation cycle, and develop action plans for performance improvement. This study will evaluate the extent and adequacy of CMS’s policies and procedures regarding the Joint Commission hospital accreditation process.

We again encourage management to periodically refer to the OIG Work Plan and use it as a tool to measure the Hospital's policies and procedures and determine if they are in check with the OIG’s interpretations. As a reference, we have included on our website a chart detailing all the topics addressed in the OIG Work Plans from 1997 to 2008. To view, click here.