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The OIG Strategic Plan for 2014-2018 Has Been Issued

The OIG Strategic Plan has been issued. (December 3, 2013): The U.S. Department of Health & Human Services (HHS) Office of Inspector General (OIG) spends a significant amount of resources to fight health care fraud and abuse.  The OIG is also tasked with promoting efficiency, economy, and effectiveness in HHS programs and operations.  Recently, the agency outlined how it will continue to meet its vision, goals, and priorities so that it can better achieve its mission in its OIG Strategic Plan, 2014-2018.  The OIG Strategic Plan sets forth four broad goals: (1) Fight Fraud, Waste, and Abuse; (2) Promote Quality, Safety, and Value; (3) Secure the Future; and (4) Advance Excellence and Innovation.  Health care providers should pay particular attention to areas in your organization that concern fraud, waste, and abuse.  Providers should also assess OIG’s priorities and strategies and implement compliance-focused protections and self-audits so that your activities comply with all health care laws and regulations. 

I.    Overview of the OIG and the Purpose of the OIG Strategic Plan:

The OIG provides independent and objective oversight of more than 300 HHS programs.  The OIG carries out its mission to protect the integrity of these programs and the health and welfare of the people served by those programs through a nationwide network of audits, investigations, and evaluations conducted by numerous offices and components. In FY 2012, OIG’s work resulted in savings and recoveries of misspent funds estimated at $15.4 billion.  A key partner, the Health Care Fraud and Abuse Control program, returned more than $7 for every $1 invested.  These results are increasingly important as the federal government seeks to improve the effectiveness and efficiency of its anti-fraud operations. 

The OIG Strategic Plan outlines the agency’s vision and priorities that guide the agency so that it can carry out its mission to “protect the integrity of Department of Health and Human Services programs and operations and the health and welfare of the people they serve.”  Along with the four primary goals outlined in the plan, the OIG Strategic Plan describes three major priorities for each goal and the OIG’s strategies for accomplishing each priority.

II. The OIG Strategic Plan is Designed to Help the Agency Fight Fraud, Waste, and Abuse:

In order to fight fraud, waste and abuse, the OIG has identified the following priorities:

  •  Identify, investigate, and taken action when needed;
  • Hold wrongdoers accountable and maximize recovery of public funds; and
  • Prevent and deter fraud, waste, and abuse.

The OIG will pursue several strategies to further these priorities.  It will build on successful enforcement models, such as the Medicare Fraud Strike Force teams, to enhance its enforcement results with other HHS programs.  Specifically, the agency will focus on key areas that include Medicare and Medicaid program integrity and waste in HHS programs.  The OIG will also continue to pursue appropriate means to hold fraud perpetrators accountable and to recover stolen or misspent HHS funds.  Accordingly, it will focus on identifying and recovering improper payments and utilizing exclusions and referrals for debarment to protect HHS programs and beneficiaries.  Finally, the OIG will apply lessons it has learned about fraud vulnerabilities and effective prevention to HHS’ new and evolving health programs.  The OIG will promote compliance with Federal requirements and resolving compliance, advising HHS on key safeguards to prevent fraud, waste, and abuse, and assessing whether providers and suppliers, grantees, and others are qualified to participate in Government programs

III.  The OIG Strategic Plan is also Aimed at Promoting Quality, Safety, and Value:

For its second goal of promoting quality, safety, and value, the OIG indicates the following priorities:

  •  Foster high quality of care;
  • Promote public safety; and
  • Maximize value by improving efficiency and effectiveness.

The Strategic Plan indicates that the OIG will expand its work efforts directed to quality of care.  The agency will focus on promoting quality of care in nursing facilities and home- and community-based settings, access to and use of preventative care, and quality improvement programs.  The OIG will also continue to prioritize fraud investigations that have public safety as well as financial implications and to look for comprehensive solutions.  In particular, the agency will continue to focus investigative efforts related to prescriptions drug fraud cases.  Mirroring other federal government initiatives, the OIG will maximize value by assessing the effectiveness of federal programs that intend to achieve value through care coordination and those that deliver and pay for beneficiary care in new ways.

IV.  The OIG Strategic Plan is Intended to “Secure the Future”:

The OIG’s third goal of “securing the future” emphasizes the following:

  • Foster sound financial stewardship and reduction of improper payments (misspent funds);
  • Support a high-performing health care system; and
  • Promote the secure and effective use of data and technology.

The agency will continue its efforts to address program and operational vulnerabilities that affect the long-term health and viability of HHS programs.  Over the next few years, the OIG will continue to prioritize work on billing and payment errors by providers, effective program administration and contract oversight, and inefficiencies that result in wasteful spending.  Furthermore, as HHS manages its transition to payments based on value rather than volume, OIG plans to conduct reviews and recommend changes to maximize overall value, protect program integrity, and foster value and high performance.  Finally, the OIG recognizes that data and technology will drive improvements in health care and human services through lower costs. Key areas of the OIG’s focus will include the accuracy and completeness of program data (e.g., Medicaid data), the privacy and security of personally identifiable information (PII), and the security and integrity of electronic health records (EHR).

V.   The OIG Strategic Plan is Intended to Advance Excellence and Innovation:

Finally, OIG wants to advance excellence and innovation in its organization and workforce through:

  • Recruiting, retaining, and empowering a diverse work force;
  • Leveraging leading-edge tools and technology; and
  • Promoting leadership, vision, and expertise.

The OIG’s final goal primarily deals with the agency’s plan related to its internal operations over the next five years.  The agency knows that to identify, understand, and address the challenges facing HHS, it will look to invest in its workforce by recruiting and retaining talented employees and by maintaining workforce excellence and the highest standards of professional conduct.  It will also seek to use the best data, analytic tools, and technologies available to maximize the impact of its work.

VI.  Final Remarks:

Overall, the OIG Strategic Plan seeks to embody the OIG’s guiding principles as it strives to ensure that Federal dollars are used appropriately and that HHS programs well serve the people who use them.  As such, this new plan outlines the agency’s priorities very broadly and largely reiterates past plans and priorities.  Nevertheless, this new Strategic Plan somewhat focuses on the OIG’s mission of fighting health care fraud and assessing and protecting program integrity as new health care payment and delivery systems evolve.

In fact, Healthcare providers are becoming all too familiar with the countless auditing organizations used by the government to combat fraud in health care related expenditures, including RACs, MICs, and ZPICs.  If the federal government believes that these entities are based on a good return for its investment in preventing or curbing fraudulent activities, stricter oversight and auditing programs are likely to increase.  The OIG may also look to enhance its exclusion capability by pursuing exclusion efforts of individual health care providers and smaller entities as opposed to larger provider entities.

Healthcare AttorneyRobert W. Liles serves as Managing Partner at Liles Parker, Attorneys & Counselors at Law.  He represented physician practices, home health agencies, hospices, DME companies and other health care providers in Medicare, Medicaid and private payor audits.  Robert also represents health care professionals in connection with State Licensure Board complaints and investigations.  For a free consultation, call: 1 (800) 475-1906.

 

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