Advisory: OIG Announces New Schedule for Updating Annual Work Plan

June 20, 2017

The U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) has announced that, effective June 15, 2017, it will provide monthly updates to its annual work plan, an increase from one or two each year.  The Work Plan – which can be found here – sets forth OIG’s fiscal year priorities in its oversight of HHS programs and grants, including audits and evaluations that are planned or underway.

The 2017 Work Plan, published in November 2016, highlighted reviews of programs implemented pursuant to legislation such as the Affordable Care Act (ACA) and the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), as well as reimbursement patterns and program integrity issues.  For more information about the 2017 Work Plan, see our advisory from the time of its release.

The Work Plan provides valuable insights into OIG’s current regulation and enforcement areas, so providers and entities participating in HHS programs or receiving funds from HHS grants will be well served by keeping an eye on updates.  For example, recent action items indicate the agency’s attention to drug prescription and reimbursement, particularly the use of and treatment for abuse of opioids and integrity in the Medicaid Drug Rebate Program.

We recommend that providers closely review the Work Plan and any updates to identify additional areas of focus for compliance efforts.  For more information, please contact a member of the Compliance Team.

The information contained in this advisory is for general educational purposes only. It is presented with the understanding that neither the author nor Hancock, Daniel, Johnson & Nagle, PC, is offering any legal or other professional services. Since the law in many areas is complex and can change rapidly, this information may not apply to a given factual situation and can become outdated. Individuals desiring legal advice should consult legal counsel for up-to-date and fact-specific advice. Under no circumstances will the author or Hancock, Daniel, Johnson & Nagle, PC be liable for any direct, indirect, or consequential damages resulting from the use of this material.