Something Old and Something New in Healthcare Compliance: The OIG Issues Its 2010 Work Plan
By Paul A. Gomez
Recently the Office of Inspector General of the Department of Health and Human Services (OIG) released its areas most in need of attention for the 2010 fiscal year. As those familiar with past OIG Work Plans may note, this years Work Plan involves a great deal of follow-up with respect to previous reviews and initiatives, as well as new areas of focus. As a guidepost to the OIGs current and future audit initiatives, the 2010 Work Plan is essential reading for compliance officers and provider administrators charged with setting audit priorities for their internal corporate compliance programs and the legal counsel who advise them. As described by the OIG, a healthy compliance program is constantly identifying new risk areas for investigation and audit. The OIG issues the Work Plan as a catalog of risk areas designed to guide hospitals and other healthcare providers and suppliers in the operation of their individual compliance plans. In the 2010 Work Plan, the OIGs audit priorities for Centers for Medicare and Medicaid Services (CMS) programs including the Medicare and Medicaid programs covers several dozen pages of densely written text. A recitation of all the priorities is beyond the scope of this Client Alert and is better left to a review of the Work Plan itself. However, the following is an abridged review of some areas of particular interest to certain healthcare providers and suppliers in the Work Plan.