Healthicity Blog

The OIG has updated their work plan in the last year more frequently than in the past and recently added nine more items in September of 2017. Anytime the OIG updates their work plan, I think it’s important to take a deep dive into the new content.

When a lot of healthcare organizations consider their risk under the False Claims Act, they often think of coding and billing errors submitted on 1500s or UBs. It’s probably the first place I’d consider looking as well for the greatest risk to a Medicare or Medicaid healthcare provider.

The field of compliance isn’t as simple as hiring honest people who will hopefully “always obey the rules.” In fact, careful hiring doesn’t constitute a compliance plan at all.

If you have a compliance program, you most likely have a full-time compliance officer or an individual who is accountable for your organization’s compliance program, even if it’s only a portion of that person’s overall duties.

Recently, compliance failures cost Florida physicians over $4 million dollars and resulted in a multi-million dollar settlement for a Tennessee hospital. The message is clear: compliance is no joke.

Many compliance programs rely on the OIG Work Plan when planning their own internal audit or compliance activities. Historically, the OIG Work Plan was updated annually. However, recently the OIG has been publishing periodic updates and additions more often.

An organization that fails to create and maintain an effective compliance program could be forced to return overpayments. And providers may face severe civil, criminal, and financial penalties.

The OIG has frequently reviewed chiropractic services over the last several years. Their most recent report was posted on their website on Aug. 18, 2017 and concluded that a Brooklyn chiropractor had a 100% error rate for claims over a two-year period worth about $672,000.