Understanding the OIG Work Plan and What It Means for Your Clinic
Every year, the Department of Health and Human Services Office of Inspector General publishes its Work Plan, a document that identifies the areas of Medicare, Medicaid, and other federal health program spending that the OIG intends to audit, review, and investigate in the coming year.
For most small clinic leaders, the OIG Work Plan is either unknown or ignored. That is a missed opportunity. The Work Plan is essentially a roadmap of where federal scrutiny is concentrated. Clinics that read it and adjust their compliance activities accordingly are better positioned than those that wait to find out the hard way.
What the Work Plan Covers
The OIG Work Plan is updated monthly and organized by program area. Items relevant to small and community-based clinics typically include:
- Evaluation and management coding patterns and upcoding trends
- Telehealth billing compliance, particularly post-pandemic policy extensions
- Opioid prescribing and controlled substance documentation
- Medicare Advantage plan billing and documentation requirements
- FQHC and rural health clinic billing compliance
- Home health and durable medical equipment referral patterns
Not every item on the Work Plan is relevant to every clinic. The value is in identifying the items that match your service lines and billing patterns and building those into your internal compliance review calendar.
How to Use the Work Plan Practically
Once a quarter, assign someone in your clinic, a compliance officer, a billing manager, or a consultant, to review the current OIG Work Plan for items that apply to your practice. For each relevant item, ask two questions: Are we doing this activity? If so, does our documentation and billing support it?
If the answer to the second question is uncertain, that is your cue to conduct a focused internal audit of that service area before the OIG does.
The Connection Between Work Plan Items and Audit Risk
OIG Work Plan items do not automatically translate into individual clinic audits. The OIG does not audit every clinic that bills for a flagged service. But Work Plan items often signal increased scrutiny from Recovery Audit Contractors and Medicare Administrative Contractors, who do conduct individual provider audits. Being on the right side of a flagged billing area before that scrutiny arrives is the goal.
What to Do Next
Visit the OIG Work Plan at oig.hhs.gov and review the current items under the Medicare Part B and Medicaid sections. Identify three items that apply to your clinic's service lines. Then ask your billing team whether your documentation practices would support those billing areas if reviewed today.
If you want support aligning your compliance program with current OIG priorities, our team can help.