Summary
The federal government invests significant resources in combating health care fraud and abuse. The U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) recently released its Strategic Plan for fiscal years 2014 through 2018. The Strategic Plan focuses upon the OIG’s mission, vision and values.

The Strategic Plan reinforces the federal government’s oversight and emphasis in ensuring federal health care dollars are spent appropriately. It provides an important reminder that health care providers can face criminal, civil and administrative penalties for non-compliance.

The Plan notes that the federal government’s Health Care Fraud and Abuse Control program has returned seven dollars ($7.00) for every one dollar ($1.00) spent by the federal government. In FY 2012, the OIG reports that its efforts “resulted in estimated savings and expected recoveries of misspent funds totaling approximately $15.4 billion.”

Providers are generally familiar with the myriad auditing organizations used by the government - RAC, MIC, ZPIC, for example. As long as the federal government believes it is getting a good return on federal dollars for its investment in stopping or curbing fraudulent activities, these oversight activities and auditing programs are likely to continue.

The Strategic Plan explains the OIG’s general goals, priorities and strategies for the next five fiscal years. The OIG identifies four primary goals: 1) fight fraud, waste and abuse; 2) promote quality, safety and value; 3) secure the future; and 4) advance excellence and innovation. As part of each of these four goals in the Strategic Plan, the OIG describes its priorities and the OIG’s strategy for accomplishing each priority.

Within the first goal of fighting fraud, waste and abuse, the OIG says that it plans to build on its current enforcement models such as the Medicare Fraud Strike Force teams, with key focus areas in Medicare and Medicaid program and integrity and waste. The OIG’s Strategic Plan states it will also continue to implement and refine protocols for self-disclosures. The Strategic Plan notes that the OIG plans to pursue holding wrongdoers accountable for their actions, with an emphasis upon identifying and recovering improper payments and utilizing exclusions and referrals for debarment.

As part of its second goal of promoting quality, safety and value, the OIG’s Strategic Plan states that the OIG will increase its work efforts directed to quality of care. Key areas of focus will include: quality of care in nursing facility and home- and community-based setting, access to and use of preventative care; and quality improvement programs. Mirroring other federal government initiatives, the OIG’s Strategic Plan includes a priority of maximizing value. To accomplish this priority, the OIG plans to assess the effectiveness of federal programs that intend to achieve value through care coordination and those that deliver or pay for beneficiary care in new ways.

The OIG’s goal of “securing the future” is an emphasis on assuring the long-term viability of HHS programs. Similar to other recent federal health care measures, the OIG has identified promoting the security and effective use of data and technology as a priority. Key areas of the OIG’s focus will include the accuracy and completeness of program data; the privacy and security of personally identifiable information; and the security and integrity of electronic health records.

The final goal outlined in the Strategic Plan is for the OIG to advance excellence and innovation. This goal primarily deals with the OIG’s plan related to its internal operations over the next five years. The OIG’s priorities include building and retaining a diverse workforce; using cutting edge tools and technology; and building leadership.

Providers should review the OIG’s Strategic Plan – http://oig.hhs.gov/reports-and-publications/strategic-plan/files/OIG-Strategic-Plan-2014-2018.pdf – to understand the OIG’s priorities and, as importantly, to make every effort to ensure their own activities comply with all health care laws and regulations. In addition to describing OIG priorities, the Strategic Plan describes the strategies the OIG will utilize to achieve its priorities. The Strategic Plan creates a compliance road map that providers should review and study as they plan business goals over the next several years.