iProtean—OIG Releases Strategic Plan

Compliance and risk management efforts of hospitals and health systems should focus on indications from the Department of Health & Human Services (HHS) Office of the Inspector General (OIG) about the direction it intends to take to investigate fraud, waste and abuse. We have talked with OIG investigators over the years who have been straightforward about the investigations. Without exception, they have said that the intention of the OIG is evident from its strategic plan.


The OIG mission is to protect the integrity of HHS programs and the health and welfare of the people they serve. It is an independent organization that fights fraud, waste and abuse and promotes efficiency, economy and effectiveness in HHS programs and operations.  Most significantly for hospital/health system compliance efforts, OIG outlines its direction in its strategic plan. The most recent strategic plan, for 2014 through 2018, was released in late November.


According to its publication, OIG’s four primary goals for 2014 to 2018 are to:

  1. Fight fraud, waste and abuse
  2. Promote quality, safety and value
  3. Secure the future
  4. Advance excellence and innovation


Fight Fraud, Waste and Abuse

OIG plans to continue to use a multi-faceted approach to prevention, detection and deterrence by building upon existing enforcement models such as the Medicare Fraud Strike Force teams.


On average, the Health Care Fraud and Abuse Control Program (a partnership with the Department of Justice and HHS), recovers more than $7 for every $1 invested and protects programs through nonmonetary results such as criminal convictions and exclusions of providers from participation in federal healthcare programs. “We will continue to pursue all appropriate means to hold fraud perpetrators accountable and to recover stolen or misspent HHS funds,” the authors of the strategic plan report noted.


Key focus areas include: Medicare and Medicaid program integrity and waste in HHS programs, identifying and recovering improper payments and using exclusions and referrals for debarment to protect HHS programs and beneficiaries, promoting compliance with federal requirements and resolving noncompliance; advising HHS on key safeguards to prevent fraud, waste and abuse; and assessing whether providers and suppliers, grantees and others are qualified to participate in government programs. It will continue to implement and refine self-disclosure protocols.


Promote Quality, Safety and Value

OIG has prioritized strategies to promote quality, safety and value:

  1. Foster high quality care: continue to evaluate and recommend improvements to the systems intended to promote quality of care; investigate and refer for prosecution cases involving abuse or grossly deficient care of Medicare or Medicaid patients. Looking ahead, OIG will expand its portfolio of work on quality of care to include promoting quality in nursing facilities and home- and community-based settings, access to and use of preventive care and quality improvement programs.
  2. Promote public safety: recommend improvements to HHS programs to ensure adequate emergency preparedness and response; protect the safety of food, drugs and medical devices; and ensure that grantees (e.g., Head Start and child care providers) meet safety standards
  3. Maximize value by improving efficiency and effectiveness: assess programs intended to achieve value through care coordination and new ways of delivering and paying for care, as well as the reliability and integrity of quality, outcomes and performance data.


Secure the Future

OIG will address program and operational vulnerabilities that affect the long term health and viability of HHS programs by:

  • Fostering sound financial stewardship and reduction of improper payments by continuing to focus on audit and review-related efforts on billing and payment errors by providers, program administration and contract oversight
  • Supporting a high-performing healthcare system to ensure better health outcomes and lower costs. It will provide technical assistance on safeguards to protect new and changing systems and programs from fraud, waste and abuse. It also plans to watch the transition to payments based on value rather than volume, and conduct reviews and recommend changes to maximize overall value, protect program integrity and foster value and high performance.
  • Promoting the secure and effective use of data and technology—emphasizing the accurateness and completeness of program data, the privacy and security of personally identifiable information and the security and integrity of electronic health records


Advance Excellence and Innovation

This goal focuses on the OIG’s inward look at its organization and operations. It intends to recruit, retain and empower a diverse workforce and also to optimize its data analytics and technology capabilities to inform its decisions about where to best direct its resources. It also will focus on building leadership and expertise to drive “positive change.”


Key Indicators to Measure Progress Towards Goals

The indicators OIG will use to measure its own progress towards its goals include:

  • Monetary return on investment
  • Cost savings
  • Individuals and entities held accountable through criminal, civil and administrative enforcement actions
  • Recommendations accepted and implemented
  • Fraud prevention and patient safety tools used
  • Advisory opinion requests resolved
  • Expected financial recoveries from investigations and audits

. . . and more.


(Information sources for this article include U.S. Department of Health and Human Services Office of the Inspector General, OIG Strategic Plan 2014-2018, and “OIG Releases Strategic Plan for Fiscal Years 2014-2018,” American Health Lawyers Association Practice Group Email Alert, December 6, 2013.) To read the 12-page strategic plan, please click the following link, or copy and paste it into your browser:  http://oig.hhs.gov/reports-and-publications/strategic-plan/files/OIG-Strategic-Plan-2014-2018.pdf




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