OIG Work Plan and Compliance Portal
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Jan 9, 2024
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OIG Work Plan and Compliance Portal
The Office of the Inspector General works planning and adjusting throughout the year to
meet priorities and respond to issues with the proper resources available. OIG’s core values are having good communication and holding accountability. OIG is committed to continuous work planning efforts. OIG does update its Work Plan website monthly. An OIG Work Plan works with various projects including OIG audits and evaluations that are be worked on or being planned on being addressed in the fiscal year and beyond by OIG’s office of Audit Services and Office of Evaluation and Inspections. Projects listed in the Work Plan
across the Department include the Centers for Medicare and Medicaid Services (CMS), public health agencies such as Administration for Children and Families (ACF) and the Administration on Community Living (ACL). OIG also is planning to implement working on work related issues that cut across departmental programs which include State and local governments use of Federal funds, as well as functional areas of the Office of the Secretary of Health and Human Services (HHS). Some work Plan items reflect work that is statutorily required. OIG assesses risks in the HHS programs and operations which identify areas that need most attention and accordingly, set priorities for the sequence and proportion of resources to be allocated. Audits and evaluations sometimes may be cancelled based off staffs availability, changes in environment, legislation that affects the issue, or recent studies the provided definitive results. When they are taking on projects, they consider several different factors such as: mandatory requirements for OIG reviews, as set forth in laws, regulations, or other directives, requests made or concerns raised by congress, HHS management or other directives. OIG also works on projects that often require audits, reviews, and reports, OIG’s work portfolio includes legal and investigative activities. They will investigate fraud, waste, abuse, facilitating compliance in the health care industry, excluding bad actors from participating in the federal health care program. OIG updates its online Work Based plan monthly. They do this to ensure that it more closely aligns with the work planning process. The monthly updates include the addition of newly implemented Work Plan items. Work plan
. Work Plan | Office of Inspector General | U.S. Department of Health and Human Services. (2019, May 15). https://oig.hhs.gov/reports-and-publications/workplan/index.asp Element 1
: Standards Policies, and Procedures. This element will periodically review policies, procedures, and controls. They also will consult with legal resources along with verifying that the appropriate coding policies and procedures are in place and exist. They also ensure each mission, vision, and values, and ethical principles apply to the code of conduct. When measuring accessibility in Standards, Policies and Procedures you should be able to review a link to an employee accessible website that includes Code of Conduct and can also readily access or reference policies and procedures.
Element 2: Compliance Program Administration maintains compliance with budgets. They also contribute to planning and preparing and monitoring financial resources. They also must report compliance program activity to the governance board/committee. The active Board of Directors will measure by reviewing minutes of meeting where compliance officer in person to the audit and compliance committee of the Board of Directors on a quarterly task. Element 3: Screening and Evaluation of Employees, Physicians, Vendors, and other Agents ensure the organization has processes in place that identify and disclose conflicts of interest. They also ensure that there is an inclusion of compliance obligations on all job descriptions. Conflict of Interests will have the organization conducting effective education on the CDI. They measure this by reviewing training materials. They will also interview staff to determine the effectiveness of the education.
Element 4: Communication, Education, and Training on Compliance Issues consists of disseminating regulatory guidance material along with communicating compliance information throughout the organization. What is measured when training? The organization Will provide risk area specific training to the employees designated to be in high-risk positions. Element 5: Monitoring, Auditing, and Internal Reporting Systems consists of protecting anonymity and confidentiality within legal and practical limits along with publicizing the reporting system to all workforce members, vendors, and agents. What should be measured with the reporting accessibility? Interviews can measure accessibility along with surveys. Asking employees and managers if the reporting system is accessible to them. Is it available in languages that are most spoken organization. Element 6: Discipline for Non-Compliance deals with recommending disciplinary action when non-compliance is sustained. Promoting discipline proportionate to violation. Fairness and consistency in disciplinary process. When measuring for example if it was an adult is the disciplinary action policy consistently followed. Element 7: Investigations and Remedial Measures communicate noncompliance through appropriate channels. Assure development of corrective action plans in response to noncompliance. The organization has guidelines established to ensure through, credible, and complete investigations are done in consistent manner. To measure you review guidelines, policy, and procedure and or protocol on investigating.
OIG has developed a series of voluntary compliance program guidance documents (CPGs) directed at various segments of the health care industry, such as hospitals, nursing homes, third-party billers, and durable medical equipment suppliers, to encourage the development and use of internal controls to monitor adherence to applicable statues, regulations, and program requirements. An ongoing evaluation process in auditing and monitoring is important to a successful compliance program. This ongoing evaluation includes not only whether the physician practices
standards and procedures are in fact current and accurate, but whether the compliance program is working and whether individuals are properly carrying out their responsibilities and claims are submitted appropriately. Therefore, an audit is an excellent way for a physician practice to a way that if any problem exists and focuses on the risk areas that are associated with problems. Claims submissions audit in addition to standards and procedures themselves, it is advised
that bills and medical records can be reviewed for compliance with applicable coding, billing, and documentation requirements. The individuals from the physician practice involved in these self-audits would ideally include the person in charge of billing and a medically trained person. Billing compliance program guidance the OIG recommended that a baseline or snapshot be used to enable a practice to judge over time its progress in reducing or eliminating potential areas of vulnerability. This practice is known as benchmarking allows practice to chart compliance efforts. The practices self-audits can be used to determine whether bills are accurately coded and reflect the services provided and are necessary.
When it comes to documentation requirements the physician needs to make sure are done it benefits everyone greatly if the standards and procedures contained a section on the retention of compliance, business, and medical records. These records include documents relating to patient care and the practices of business activities. Safe harbor defines practices that are not subject to the anti-kickback statue, because such a situation is unlikely to result in fraud or abuse. Safe harbor sets forth specific conditions that if fully met would ensure entities involved of not being prosecuted. On March 22, 2021, OIG issued a notification of the court ordered delay of the effective date of this final rule. These amendments have been delayed until January 1, 2023. Federal Register / Vol. 65, No. 194 /
. https://oig.hhs.gov/reports-and-publications/workplan/index.asp. (n.d.). https://oig.hhs.gov/documents/compliance-guidance/801/physician.pdf Work plan
. Work Plan | Office of Inspector General | U.S. Department of Health and Human Services. (2019, May 15). https://oig.hhs.gov/reports-and-publications/workplan/index.asp
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