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How the OIG Work Plan Works For You

Compliance is a top priority for all health care organizations, and finding ways to stay compliant with HIPAA privacy and security standards without completely disrupting your office and re-designing common processes is not an easy task.  There is no doubt that proper billing habits in today's medical practices and hospitals are intricate and crucial to survival. One false step can be detrimental to the overall health of your organization.

Luckily, there are resources available designed specifically to make compliance a little easier; in particular, the Work Plan by the Office of the Inspector General (OIG), a free resource from the government. 

The OIG was created by Congress in order to protect the integrity of services provided by the Department of Health and Human Services (HHS) and the beneficiaries it serves. The OIG reports its findings to the Secretary of HHS and to Congress, and it carries out its duties nationwide through audits, investigations, and inspections. 

Divided into roughly twenty sections, the OIG Work Plan identifies focus areas that will garner the most attention and investigation each year at hospitals, physician practices, home health agencies, and other providers of healthcare.  The areas identified in the 2006 plan include items that are listed every year as well as new items, such as the relationship between billing companies and physicians, Medicare payments to VA physicians, physical and occupational therapy services, wound care services and “long distance” physician claims.   The OIG selects topics for the Work Plan that have significantly increased in volume over previous years, that commonly contain errors when billed, and that are confusing to physicians and carriers.  It is virtually guaranteed that there are items on the list that affect your organization some way. 

Sure, at first reviewing and understanding the Plan may seem a daunting task.  That is why we are offering you a few tips on how to make the Plan work for you:

• Use the OIG Work Plan as the foundation for your Compliance Plan.  All practices have a Compliance Plan but hopefully it is not something that is sitting on a shelf collecting dust.  Your Compliance Plan should be updated regularly, in conjunction with the OIG's Work Plan.  Each October when the OIG issues its plan for the upcoming year, be sure that you identify in it all of the areas that affect your practice and revise your plan according to specific areas of interest for the coming year.
• Reach out to the OIG.  The agency actually encourages you to contact them with questions or concerns - after all, they are here to help.  You can call or email their hotline with questions at any time. 
• Subscribe to the OIG email list. The OIG issues periodic notifications of additions to the OIG Internet site via email to healthcare organizations, media, attorneys, and practically anyone who needs to know.  Reading the executive summaries of several of the OIG reports is an efficient way to determine if issues relate to your organization.  Sign up here.
• Networking.  You should not underestimate the significance in utilizing your network of fellow compliance and audit professionals to help define the steps necessary to ensure that your business is effectively managing those risks identified in the OIG Work Plan.   Fellow healthcare professionals are a wealth of knowledge that should be tapped into for a quick review and/or discussion of your compliance plan from a peer perspective. 
• Assign a compliance committee.  Forming a respective compliance committee to identify the process and/or tools through which you will manage or track your progress in accomplishing the activities listed on your compliance plan, including the process of reporting status of the activities. 

It is in every facility's best interest to take advantage of and properly utilize this "sneak peek" at the government's hot buttons for the year.  It is fundamental in billing to be proactive with your procedures.  So reviewing the Plan and then implementing programs to help you stay compliant with each of the areas that affect your organization will help you stay on track, stay compliant, and stay profitable - and stay out of the hot seat in an audit.