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On October 1, 2007, the Department of Health and Human Services (HHS) Office of Inspector
General (OIG) issued its 2008 annual Work Plan, which outlines the key focus areas and projects the
OIG intends to pursue during the 2008 fiscal year (FY 2008). The OIG Work Plan is available in its
entirety from the OIG website.
Approximately 80 percent of the OIGs resources are devoted to projects within the Medicare and
Medicaid programs. These projects include audits, evaluations, investigations, and legal activities.
This article will highlight a few of the areas within the Medicare and Medicaid programs that the
OIG identified as focus areas for FY 2008. Physicians and other healthcare providers and suppliers
providing services billed to Medicare and Medicaid are well-advised to review the sections of the
Work Plan applicable to the services they provide, and review their existing compliance efforts, in
the context of anticipated OIG activity for the upcoming year.
Although the 2008 Work Plan outlines the OIGs intended areas of activity for the fiscal year ahead,
the OIG also has noted that work planning is a dynamic process that continues after the publication
of its annual Work Plan. Thus, after analyzing current events and emerging issues as they arise, the
OIG may add new activities or cancel or delay planned activities, as it deems appropriate. At the
time of the Work Plans publication in October 2007, the OIG announced that it would focus on the
following issues related to Medicare and Medicaid, among others, during FY 2008:
A. Medicare
1. Hospitals
As in previous annual Work Plans, the OIG outlined several areas of focus and initiatives it has
planned for FY 2008 regarding Medicare payments made to hospitals.
New in the 2008 Work Plan, the OIG articulated heightened interest in Medicare payments made to
long-term care hospitals. Accordingly, long-term care hospitals may see increased investigations and
audit activity during FY 2008. The OIG enumerated multiple areas of focus with respect to these
hospitals.
Also in FY 2008, the OIG will review physician-owned specialty hospitals for indicators of patient
care and safety. The OIG cited concerns raised about the appropriateness of care and about whether
staffing levels were appropriate at specialty hospitals.
2. Home Health Agencies
The OIG will review national data collected regarding home health agencies survey and certification
findings, particularly with respect to any findings of deficiency. The OIG will consider whether
agencies with a history of noncompliance with certification standards perform differently during
cyclical survey and certification than agencies without a history of noncompliance with certification
standards. This analysis will be conducted in an effort to determine whether sanctions are effective
when placed upon agencies with findings of deficiencies.
The OIG will also consider whether services billed by home health agencies were appropriately
coded, fully documented, and properly billed.
The management challenges specified by the OIG include all of the following:
Oversight of Medicare Part D
Integrity of Medicare Payments
Appropriateness of Medicaid and SCHIP Payments
Medicaid Administration
Quality of Care
Public Health Emergency Preparedness and Response
Oversight of Food, Drug, and Medical Device Safety
Grants Management
Integrity of Information Technology Systems and Infrastructure; and
Ethics Program Oversight and Management
Notably, Medicare providers and suppliers practicing in the areas listed above should be aware that
there is even more governmental scrutiny on these areas than on other areas outlined in the 2008
Work Plan. The OIG is actively taking steps to address these perceived risk and management
challenges.