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Time to review the 2013 OIG work plan

December 4, 2012
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A few days ago, the Office of Inspector General (OIG) announced, as a part of its Semiannual Report to Congress, that it expects recoveries to amount to $6.9 billion this year.  (Yes, that’s “billion” with a “b”!) This impressive haul is a result of fraud investigation and audits. A portion of this came from the Medicare Fraud Strike Force, whose investigative efforts resulted in criminal charges against some 305 entities or people and 181 convictions (a conviction rate of over 59 percent).

With all these activities and recoveries, it’s no wonder that the OIG is continuing its aggressive efforts to identify fraud among healthcare providers. When you add the writ of qui tam or “whistleblower” provision, which allows people who are not affiliated with the government to file actions against federal contractors claiming fraud against the government, it makes for a daunting investigative force that’s not exactly friendly in the eyes of long-term care (LTC) providers.

What are providers to do? Well first, it should go without saying (but I’m going to say it anyway) that all providers must have an active and effective compliance program in place. If you don’t, drop whatever you’re doing right now and start putting one together. A good place to start is the OIG website, which can give you guidance on assembling your compliance program.

For the vast majority of you who already have a solid compliance program in place (good job by the way), it’s a good idea to review the OIG work plan. In October, the OIG released its 2013 work plan, which outlines the audit and enforcement initiatives for Medicare and Medicaid providers in the coming year. In reviewing this work plan, it gives providers some insight into the activities that the OIG is going to emphasize in the coming period and thus, gives providers guidance on areas to focus on in their compliance programs.

The Nursing Homes section of the work plan outlines eight initiatives that specifically address compliance risk areas for Medicare and Medicaid providers in the skilled nursing industry. Of these eight focus areas in the 2013 OIG work plan, there are three new projects:


The OIG will seek to determine if the state survey agencies have verified correction plans for deficiencies identified during nursing home recertification surveys, as required by federal law. During a prior OIG survey, it was discovered that a state survey agency did not conduct this verification.


The use of antipsychotics on LTC residents has received a substantial amount of legislative and regulatory attention recently. The OIG will conduct assessments of the administration of these drugs and such assessments will include the percentage of residents receiving these drugs as well as the types of drugs most commonly received.


Craig Fukushima

Craig Fukushima



Craig T. Fukushima, NHA, is partner at The Fox Group, a consulting practice that serves a wide...