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 2012 fiscal year. As a guidepost to the OIGs current and future audit initiatives, the 2012 Work Plan is essential reading for compliance officers, legal counsel and provider administrators charged with setting audit priorities for their internal corporate compliance programs. 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 2012 Work Plan, the OIGs audit priorities for 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 in the Work Plan.