This review of the OIG FY2016 Work Plan will provide the various section(s) that were identified by the OIG that may affect the specialties of Anesthesia and Pain Management. It does not include a comprehensive review of all components of the Work Plan. This document is for “informational use only” and it is not intended to provide legal advice or counseling on the various topic(s). If the reader has concerns or questions they should consult with their legal counsel for advice.
The OIG released its Fiscal Year 2016 (FY2016) Work Plan in October, 2015. The work plan is published annually and provides the OIG’s current ongoing audit and enforcement initiatives as well as identifying any new priorities for the upcoming year. The work plan is a very useful tool in indentifying compliance risk areas and focus for ongoing efforts relating to compliance program activities, audits and policy development.
The OIG states that the purpose of the work plan is in part to provide brief descriptions of the activities the OIG intends to either initiate in FY 2016 or intends to continue from previous years as it exercises its oversight authority. The work plan is at its heart an allocation of resources to combat waste, fraud and abuse. How successful is the OIG in combating waste, fraud, and abuse? They reported for FY 2015 expected recoveries of more than $3 billion ─ $2.22 billion in investigative work and $1.13 billion in audit work. Also reported for FY 2015 were 4,112 individuals excluded from participating in Federal healthcare programs, along with 925 criminal cases and 682 civil cases related to criminal activities, false claims and unjust enrichment lawsuits.1
It is important again to note that the items selected in this document contain only those that may pertain to Anesthesia and Pain Management (directly or indirectly). Providers are encouraged to read the full work plan to better assess their own individual business activities against the work plan. View a complete version of the OIG Work Plan (PDF, 4.3 MB).
The OIG may periodically make updates during the year to the Work Plan. As they make adjustments to the work plan, they do not provide status reports on their reviews. At any time, you can view updates to the plan by visiting: http://www.oig.hhs.gov.
This summary is presented in three sections:
1. Medicare Parts A and B
- Anesthesia or Pain Management Specific
3. Centers for Medicare and Medicaid (CMS) Related Legal and Investigative Activities
Under each section, we provide the projects, as written by the OIG, that we believe to be of interest. Text emphasis was added to bring attention to the reason why the project was added. Some projects included are the OIG’s oversight of CMS, Medicare Administrative Contractors (MACs) and Medicare Advantage. These are included because it is expected they may be a catalyst for additional physician oversight from these entities. We are all aware of the OIGs efforts to ensure procedures are medically necessary. However, the OIG’s goal of reducing fraud, waste, and abuse goes further and also includes improving the quality of care and patient safety.
Download the complete summary of the OIG FY2016 Work Plan for Anesthesia and Pain Management (PDF, 185 KB).