Policy & Regulation News

OIG Releases 2015 Work Plan for CMS Investigative Initiatives

By Ryan Mcaskill

The fiscal year of 2015 will include audits, evaluations and other legal investigative members of HHS agencies.

- The U.S. Department of Health and Human Services (HHS) Office of Inspector General has released its “Work Plan” for the fiscal year of 2015. This is a report that summaries the audit, evaluation and other legal and investigative initiatives that the OIG intends to conduct in the coming year.

The 90 page document outlines a number of different reviews of the Centers for Medicare and Medicaid Services (CMS), Food and Drug Administration (FDA) and other HHS agency programs, with a particular focus on Medicare and Medicaid reimbursement and program integrity policies. It also forecasts areas that may be the subject of review in future years including emerging Affordable Care Act marketplace issues, Medicaid expansion and new Medicare payment and delivery models. Other areas under consideration for new reviews include the integrity of the drug and medical device supply chains and the security of electronic devices.

“Our organization was created to protect the integrity of HHS programs and operations and the well-being of beneficiaries by detecting and preventing fraud, waste, and abuse; identifying opportunities to improve program economy, efficiency, and effectiveness; and holding accountable those who do not meet program requirements or who violate Federal healthcare laws,” the report read.

The goal of the OIG is to encompass more than 100 programs administered by HHS. The amount of work conducted in each category is set by the purpose limitations in the money appropriated to OIG. This funding is directed toward oversight of the Medicare and Medicaid programs constitutes a significant portion of its total funding (an estimated 76 percent in 2014).

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  • The working planning itself is a dynamic process, with adjustments made throughout the year to meet priorities and anticipate emerging issues. Relative risks are assessed in the programs OIG has oversight authority to identify areas that need attention. With the work plan, several factors are considered. They include:

    •Mandatory requirements for OIG reviews, as set forth in laws, regulations and other directives

    •Requests made or concerns raised by Congress, HHS management of the Office of Management and Budget

    •Top management and performance challenges facing HHS

    •Work performed by partner organizations

    •Management’s actions to implement our recommendations from previous reviews

    •Timeliness.

    In the fiscal year 2014, the work planning identified $15.7 billion in savings on the basis of prior-period legislative, regulatory or administrative actions that were supported by OIG recommendations. OIG reported exclusions of 4,017 individuals and entities from participation in federal healthcare programs, 971 criminal actions against individuals or entities that engaged in crimes against HHS programs and 553 civil actions, which include false claims and unjust-enrichment lawsuits filed in Federal district court, CMP settlements and administrative recoveries related to provider self-disclosure matters.

    This new Work Plan is effective as of October 2014 and contains hundreds of projects. The focus will continue to be emerging payments, eligibility, management and IT systems security vulnerabilities in healthcare reform programs.