2015 OIG Work Plan

Today, the Health and Human Services Office of Inspector General published their 2015 Work Plan.  This work plan outlines the substantive audits planned by the OIG in various provider arenas.

Below is a summary of the new activities and recurring issues for hospitals and physicians.


The OIG added one new issue to the work plan for hospitals.  The OIG is planning to evaluate the impact of the “2 Midnight Rule” on hospital billing, Medicare payments and beneficiaries.

The OIG plans to continue the following activities for hospitals:

  • Reconciliations of outlier payments – The OIG will continue their reviews of outlier payments made to hospitals to determine the appropriate payments were made and the resulting cost-to-charge ratio is acceptable.
  • Medical device credits – There continues to be focus on the cost to the Medicare program for defective devices, as well as those for which manufacturer credit is available.
  • Provider-based status – Hospitals will continue to be under review for the appropriate designation of provider-based status to those locations off campus, including physician practices.
  • Critical Access Hospital swing bed services – The OIG continues to focus attention on the appropriate use of swing bed services in Critical Access Hospitals.
  • Inpatient and Outpatient billing – Comprehensive compliance audits conducted by the OIG at selected hospitals will continue in 2015.  These audits focus on high volume/high risk billing requirements including short stays, mechanical ventilation, outpatient surgery, and other areas prone to overpayment.
  • Quality initiatives – The OIG continues to seek to assure quality care is provided by all aspects of the provider community.  They have specifically highlighted oversight of pharmacy compounding, hospital privileges and adverse events.


The OIG plans to continue the following activities for physician services:

  • Physician billing and coding, including place of service and use of modifiers.
  • Imaging services, including utilization of high-cost services and portable x-ray equipment will be reviewed.
  • Independent physical therapy providers documentation for medical necessity.
  • The review of provider compliance with 340B drug purchasing requirements.
  • The OIG remains committed to reviewing the appropriate billing of outpatient drugs, including units and documentation of administration.

We recommend Medicare providers review the Work Plan for Fiscal Year 2015 in its entirety. We also recommend providers conduct proactive audits of the applicable areas identified in the newest work plan.  To read the complete OIG Fiscal Year 2015 Work Plan, please click on the following link:  http://oig.hhs.gov/reports-and-publications/workplan/index.asp

HC Healthcare Consulting staff includes certified coders, physicians, consultants certified in healthcare compliance and statisticians that are available to provide expert assistance with your Medicare and Medicaid compliance programs.

DISCLAIMER: This post contains only summary information and highlights; it should be read in conjunction with the full article or document provided as a link. Any advice or recommendations given is general and specific questions should be directed to professional counsel.

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