The OIG Workplan and Building Your Coding Compliance Plan/Program

Gloryanne Bryant, RHIA, CDIP, CCS, CCDS Compliance Leave a Comment

The OIG Workplan and Building Your Coding Compliance Plan/Program

Each year the Office of Inspector General (OIG) publishes their healthcare workplan and this is an “opportunity” for us in review and learn from their areas of focus. The workplan can be viewed at: Work Plan | Office of Inspector General | U.S. Department of Health and Human Services ( In addition, the OIG updates their workplan on a monthly basis, so focused areas can change (or be added) thus it requires us to ensure we check the OIG website each month.

The work plan covers many healthcare areas of Department of Health and Human Services (HHS), so if you work in an acute care hospital ONLY, then you will have a narrower focus, compared to if you represent or work for a healthcare corporation that has multiple Hospitals, Rehab facilities, Clinics, SNF’s, etc. If you have many types of healthcare sites and services you will be looking more broadly. During the work plan review process, hi-light or put all areas or targets on a spread sheet (excel), creating a list; it is also best to list them by setting i.e., Hospital Inpatient, Hospital OP, Physician, SNF, etc.

Be sure to discuss them with your staff and leadership, comparing them to your own healthcare operations, compliance targets and healthcare settings. As you build your coding compliance plan or program also look at the OIG reports that have been published throughout the year, as these are often the results of prior OIG work and are red flags (i.e., SNF 3-day window), which may not be in the actual 2021 work plan but came from a work plan 3-4 years prior.

For 2021 we see that Telehealth, 2 Midnight rule, Lab billing for COVID, COVID inpatient add on payment are areas of OIG focus, so these should be included in your coding compliance plan. This means that auditing, monitoring and education in these specific areas are needed at a minimum. Keep in mind that there are several other governmental published reports on healthcare compliance targets and risks, so be sure to review those also (i.e., CERT, PEPPER, RAC, RADV) and add or revise your coding compliance plan accordingly.

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