The OIG's Modernization Efforts: What Our Expert Learned at the Roundtable Event

The OIG Wants Your Feedback on How to Improve

The U.S. Department of Health and Human Services (HHS) OIG is modernizing, or at least they’re seeking feedback on how to do so. In September 2021, the OIG published a formal “Request for Information” in the Federal Register. Officially, the announcement was titled, “OIG Modernization Initiative To Improve Its Publicly Available Resources—Request for Information.”

Essentially, the OIG is asking the public and compliance community for feedback on modernizing and improving their sharing of publicly available resources. Think of the last time you visited the OIG’s website. What did you like? What didn’t you like? What do you wish they shared that they currently aren’t sharing? Or would you prefer they shared their information through a different avenue, phone app, or other technique? Well, that is what this Request for Information (RFI) is for. They want feedback and ideas on how to improve.

In addition to allowing the public to submit written comments online, the RFI also stated, “Notably, this RFI is just one action we are taking to gather input. We intend to conduct roundtables and are considering other ways to collect feedback, such as performing user surveys regarding targeted aspects of our data.” I was fortunate enough to participate in one of these roundtables.

What I Learned From the HHG OIG Modernization Roundtable Event

In my personal experience, the OIG was “all ears.” They prepared questions and inquiries for us, but they carefully listened to all our comments and suggestions, even the unsolicited ones.

Here are just a few of the things I suggested:

    1. The enforcement news that OIG shares is a resource I utilize frequently. As compliance officers, we are trying to demonstrate to our boards and executive leadership the types of non-compliance that can occur and the accompanying fines or penalties associated with non-compliance. Many of the OIG's enforcement examples on their website link to DOJ Press Releases, which often provide more detail about the case or scenario at hand. However, when there is not a DOJ Press Release associated with the enforcement, the information the OIG shares is minimal (here is an example). I requested they share (as much as is allowed) more details about the enforcement, such as how it was discovered, who and what type of individuals were involved, the specific areas of non-compliance, and why the action was non-compliant. How can non-compliance be addressed? What are best practices?
    2. Data sharing—I love data! For example, I shared how well CMS presents its Open Payments Data, which I am mining for potential conflicts of interest or other potential non-compliance. I know the OIG uses and mines billing and coding data (among different data types). I recommended they share, again as much as is possible, data trends, specific medical codes or code pairs, coding modifiers, diagnosis codes, and any other billing data that we could use as compliance professionals to drill down within our organizations to identify possible non-compliance. In other words, make both the data and the analytic data procedures available to us to mine our data in a similar fashion. They are already doing this with opioid prescribing data (example here) when they’ve shared the actual computer programming codes to assist users in analyzing large datasets of prescription drug claims to identify individuals at risk of opioid abuse or misuse.
    3. Work Plan organization, searchability, and filtering convenience. The work plan is a commonly used resource by most compliance professionals. The OIG does a great job announcing newly added items to the work plan. However, as all these new items get added, it would be nice to have a user-friendly dashboard to filter based on provider type, issue type, code, or other keywords. Similarly, as the work plan items are completed, and written reports are issued, it would be nice to add them to a “one-stop-shop” dashboard or tool.

Sharing Information Is A Great Learning Experience In Itself

I could go on and on about the great feedback and ideas shared in the round table group I participated in. I am excited to read the many comments and suggestions submitted to the OIG, as they will most likely publish many of these comments. Even if the OIG doesn’t act on the suggestions, I am sure there will be “gems” found in all the comments that we might act on in our spheres of influence. Or, the ideas might prompt other ideas and brainstorming that will lead us to other creative solutions ourselves. Either way, the practice of asking for feedback, sharing, and reviewing what has been shared can be a learning experience in and of itself.

 

To download this blog as a PDF, click the button below.

Download the PDF

Questions or Comments?