4 Key Areas to Watch in the June 2025 OIG Work Plan Update

The OIG added some new Work Plan items that compliance teams should keep on their radar. Here are a few key updates. 

Medical Directors at Nursing Homes

In June 2025, the OIG added another nursing home item to their Work Plan. True to their word, they appear to have increased their watchdog work on nursing homes. This time, the Work Plan item involves the reporting of the hours worked by medical directors at nursing homes. The OIG states that these medical directors have the responsibility for implementing resident care policies, coordinating medical care, and participating in quality assessment and assurance activities.  

Nursing homes are required to report hours worked by medical directors to CMS's Payroll-Based Journal (PBJ) and, based on reported hours, concerns have been raised about nursing homes' employment and engagement of medical directors. The OIG admits there may be limitations to the accuracy and utility of PBJ data on medical director hours. Consequently, this Work Plan item will assess three things: 

1. The extent to which medical directors performed required duties in nursing homes, 
2. The extent to which PBJ data on medical director hours are accurate and useful for oversight, and 
3. Opportunities to improve oversight and transparency of nursing homes' engagement and funding of medical directors through existing data or other monitoring mechanisms. 

Health Risk Assessments and Medicare Advantage 

Medicare Advantage (MA) is the other sector of the healthcare industry that the OIG has been emphasizing in their work. In some high-need patients who have dual eligibility for both Medicare and Medicaid special plans have been created. These plans are called Dual Eligible Special Needs Plans (D-SNPs). 

In most cases, there is a potential for D-SNPs to receive higher MA payments. D-SNPs must fulfill certain care coordination requirements that do not apply to non-SNP MA plans. This includes a requirement to maintain procedures for care coordination activities following enrollee health risk assessments (HRAs). 

This Work Plan item is designed to determine the extent to which D-SNPs received 2025 risk-adjusted payments for diagnoses reported only on HRAs. They also want to check if select plans complied with certain care coordination requirements. 

Parenteral Nutrition

Sometimes patients need to receive nutrition directly into a vein. This is called parenteral nutrition. For a two-year period, Medicare Part B paid more than $487 million for parenteral nutrition. During those same years, CMS's Comprehensive Error Rate Testing reports identified improper payments due to a lack of documentation showing medical necessity, coding errors, and insufficient or no documentation. With that in mind, the OIG is going to evaluate whether Medicare paid suppliers for parenteral nutrition in compliance with Medicare’s requirements. 

Kidney Transplant Waitlist 

When a hospital with a Medicare provider agreement has a transplant program, they must follow Medicare’s Conditions of Participation (CoPs). One of the CoP requirements is that transplant programs use written patient selection criteria to determine a patient's suitability for placement on the transplant waiting list.  

Because CMS does not define the selection criteria, there are questions about what they include, how they vary, and why patients fail to meet them. This is why the OIG will study and provide information about transplant programs' patient selection criteria for adult kidney transplants. They will also study the reasons that patients are not added to the waitlist following an evaluation for transplant. 

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