Jan Elezian (jan.elezian@sunhawkconsulting.com) is a consultant and Director at SunHawk Consulting LLC.
Just as your compliance department compiles an annual road map for work projects engineered to minimize risk to the organization, the federal government requires an annual road map from the Office of Inspector General (OIG). Its road map, or Work Plan, is tactical in nature and designed to outline the federal government’s expectations for upcoming management. Projects are gleaned from information received from a variety of sources, including the OIG’s fraud, waste, and abuse hotline; departmental and Government Accountability Office and Department of Justice referrals; billing data; Congressional requests; and referrals from whistleblower disclosures. Projects are planned to be addressed during the fiscal year and beyond by the OIG’s Office of Audit Services and the Office of Evaluation and Inspections. The OIG Work Plan thus becomes an important resource and reference for healthcare compliance programs when developing their internal and external auditing plans.
Projects in the Work Plan include the Centers for Medicare & Medicaid Services (CMS), public health agencies such as the Centers for Disease Control and Prevention and National Institutes of Health (NIH), and human resources agencies such as Administration for Children and Families and the Administration for Community Living. Work related to state and local governments’ use of federal funds and the functional areas of the Office of the Secretary of the U.S. Department of Health & Human Services (HHS) are included in relevant Work Plan items.[1]
Through its mission to protect the integrity of HHS programs and the health and welfare of the people served by those programs, OIG includes legal and investigative efforts in its plan. Efforts include investigating fraud, waste, and abuse; facilitation of compliance in the healthcare industry; and efforts to exclude bad actors from participating in federal healthcare programs.
To meet rising priorities, the OIG planning anticipates emerging issues and adjustments that must be made throughout the year. In the past, the Work Plan was adjusted once or twice each year. Now, effective June 15, 2017, the OIG updates the plan monthly on its website. Visit the OIG website to see a sample of the latest updates, active audits, and archive.[2]
The monthly update places newly initiated items on the “Recently Added” page. Completed plan items remain on the active Work Plan for one month, then move into the archive. Table columns are separated into:
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Status (completed, revised, active, and date announced),
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Agency (i.e., CMS, Indian Health Service, Office of the Secretary, Health Resources and Services Administration, Centers for Disease Control and Prevention, etc.),
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Title of audit (with summary of audit intent available through a hyperlink),
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Component (i.e., Office of Audit Services, Office of Evaluation and Inspection),
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Report number(s), and
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Tags (e.g., quality, COVID-19, public health issues, emergency preparedness, financial stewardship, children and family grants).
