The United States Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) released its Fiscal Year 2015 Work Plan (“2015 Plan”) on October 31, 2014. OIG releases a work plan annually to identify the new and ongoing investigative, enforcement and compliance activities that it will undertake during that fiscal year (“FY”).
Takeaways From OIG’s Work Plan
When analyzed and applied effectively, the 2015 Work Plan can be a valuable resource for health care organizations. New initiatives indicate OIG’s new priorities. However, continuing initiatives emphasize OIG’s continued – and potentially heightened – interest in areas of focus.
Organizations should consider developing internal audit and compliance plans based on OIG’s initiatives, including an analysis as to how new and continued initiatives may highlight trends or important areas of focus for the organization. OIG’s Work Plan should not be the only compliance guidelines an organization uses for its internal initiatives, but OIG’s focus on specific initiatives (including the degree of specificity of OIG’s focus) can help an organization shape its compliance program for the coming year.
The remainder of this Update will provide a summary of some of OIG’s initiatives as outlined in the 2015 Plan.