In its recently issued 2011 Work Plan, the Office of Inspector General (OIG) provides a detailed description of areas where the agency will focus its enforcement resources over the coming year. Some of the enforcement priorities defined in the 2011 Plan are based on statutory mandates to target particular areas, while others reflect the OIG’s assessment of “relative risk” in the Medicare and Medicaid programs.
The 2011 Work Plan describes a sweeping array of initiatives, and suggests that the OIG will focus its efforts on: (1) ensuring compliance with certain highly technical billing and reimbursement requirements; (2) analyzing whether services are being provided at substandard levels of quality and with insufficient levels of documentation; (3) addressing compliance with some of the electronic health record provisions adopted in the 2009 Recovery and Reinvestment Act; and (4) implementing various program integrity standards enacted under 2010’s Affordable Care Act. Meanwhile, the subtext of the 2011 Work Plan is a continued focus on targeting particular types of providers who, for one reason or another, are perceived to pose heightened risks of fraud and abuse. The 2011 Plan includes the following specific initiatives:
The full Work Plan can be found on the Office of Inspector General Web site and contains a variety of other initiatives in addition to the ones noted above. If you have questions about any of the OIG’s 2011 enforcement priorities, please contact Jesse Berg (firstname.lastname@example.org, 612.632.3374) or Tim Johnson (email@example.com, 612.632.3208).
This article is provided for general informational purposes only and should not be construed as legal advice or legal opinion on any specific facts or circumstances. You are urged to consult a lawyer concerning any specific legal questions you may have.
Gray Plant Mooty is recognized as one of the leading corporate law firms in Minnesota and one of the top franchise firms in the world. Our roots go back to 1866. Today, we are a 180-plus attorney, full-service firm with offices in Minneapolis and St. Cloud, Minnesota; Washington, D.C.; and Fargo, North Dakota.