OIG Publishes Fiscal Year 2012 Work Plan


Last week, the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) published its work plan for the 2012 fiscal year in which it described its primary objectives for the year. We identify below, by industry sector, certain key objectives that are likely to raise issues for companies and providers during the coming year. All activities identified in the 2012 work plan will not be completed within 2012; however, they are traditional indicators of where the federal government will be focusing efforts to study and prevent fraud, waste, and abuse for the foreseeable future.

I. Pharmaceutical Industry

The OIG has identified a number of 2012 objectives that could potentially impact the pharmaceutical industry. Among these objectives are items relating to pricing of and payment for pharmaceuticals, rebates offered on pharmaceuticals, and actions taken by government agencies including plans to:

Pricing and Payments

- Review Medicare Part B drug prices by comparing Average Sales Prices (ASP) to Average Manufacturer Prices (AMP) and Widely Available Market Prices (WAMP) to determine if the ASP exceeded either the AMP or WAMP by a designated threshold of 5%;

- Determine the percentage of manufacturers that complied with the AMP reporting requirements to evaluate if increased enforcement by OIG and the Centers for Medicare and Medicaid Services (CMS) impacted reporting rates;

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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