This is the last of three blog posts summarizing the fiscal year 2015 plans of theOIGWP1-300x154Office of Inspector General (OIG) of the U.S. Department of Health & Human Services (HHS). The first two posts (post one, post two) covered the OIG’s plans for oversight of the Medicare and Medicaid programs. This post covers legal and investigative activities and reviews of public health and human services agencies.


Affordable Care Act (ACA) Reviews

In 2015, OIG plans to implement at least five to 10 additional reviews of ACA programs. These programs may focus on —

  • Emerging marketplace issues, such as potential vulnerabilities in the second open enrollment period;
  • Implementing additional marketplace functionality, such as the redetermination process or premium stabilization;
  • Medicaid expansion;
  • New Medicare payment and delivery models; or
  • New grant programs.


Recovery Act Reviews

OIG will continue its oversight of HHS programs that receive funding through the Recovery Act, including reviewing or auditing incentive payments for Medicare’s adoption of electronic health records, the security of electronic health records, and grant and contract fraud.


Legal and Investigative Activities

The OIG will continue its legal and investigative activities in fraud cases in 2015, including —

  • Working with the Department of Justice (DOJ); the Federal Bureau of Investigation, and State Medicaid Fraud Control Units;
  • Issuing advisory opinions;
  • Providing guidelines for provider self-disclosure of fraud, waste or abuse; and
  • Conducting criminal, civil and administrative investigations related to more than 100 HHS program, including investigations of Medicare and Medicaid fraud.


Agency Reviews

OIG reviews public health and human services agencies within HHS. In 2015, areas of focus will include reviews of —

  • Agency for Healthcare Research and Quality
    • Patient safety organizations;
  • Centers for Disease Control and Prevention
    • World Trade Center Health Program claims;
    • President’s Emergency Plan for AIDS relief;
    • Compliance with grants requirements;
    • Controls over property; and
    • Security of pharmaceutical stockpiles;
  • Food and Drug Administration
    • Inspections of generic drug manufacturers;
    • Post marketing drug application studies and testing;
    • High-risk food facilities inspection; and
    • Clinical trial reporting compliance;
  • Health Resources and Services Administration
    • Community health center compliance with Affordable Care Act grant requirements;
    • Duplicate discounts for 340B drugs; and
    • Health Center Program grantees compliance issues;
  • Indian Health Service
    • Hospital inpatient care;
  • National Institutes of Health
    • Use of Superfund money;
    • Construction grants;
    • Review of selected colleges and universities;
    • Grants management; and
    • Proper use of appropriated funds;
  • Substance Abuse and Mental Health Services Administration
    • Block grant program;
  • Hurricane Sandy Disaster Relief Act
    • New in 2105, OIG will perform audits of grantees;
    • Use of volunteer medical personnel;
    • Assess HHS block grant guidance; and
    • New in 2015, determine hospitals’ compliance with HIPAA;
  • Department of Justice
    • OIG will continue to assist DOJ in resolving civil and administrative fraud cases;
  • Administration for Children and Families
    • Tribal Family Assistance Plan compliance;
    • Foster care and adoption assistance payments;
    • State oversight of health care for children in foster care;
    • Child support enforcement;
    • New in 2015, emergency plans for childcare services and programs; and
    • Head Start grant competition;


HHS Financial and Information Services Reviews

OIG will review various aspects of HHS’s grant management, compliance with reporting requirements, audits, and information security and vulnerability to hackers.

The issues in the new work plan are quite important for all medical practices and professionals to keep in mind as we enter 2015. If you need assistance interpreting how the plan will impact your practice, please call one of Seigfreid Binghams’s Health Care Attorneys today!

Image: HHS/OIG

*This article is very general in nature and does not constitute legal advice. Readers with legal questions should consult with an attorney prior to making any legal decisions.