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How Often Should Physician Practices Review the OIG Work Plan?

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Medical Question

"The OIG Work Plan feels overwhelming. Every time I look at it, there are dozens of projects and audit topics. Is this something physician practices should actually monitor? How often should I review the OIG Work Plan, and how can we use it to reduce risk in our practice?"

Medical Answer

Yes, physician practices should regularly review the OIG Work Plan.

The OIG Work Plan gives physician practices something incredibly valuable: A preview of where the government is looking.

Think of it as a roadmap. The Work Plan won’t tell you exactly which practice will be audited next. But it often reveals which services, specialties, billing issues, and compliance concerns are attracting government attention.

It’s generally recommend reviewing it at least monthly because new projects, audit priorities, and enforcement concerns can be added throughout the year. Monitoring the Work Plan helps practices identify emerging risks before they become audit findings.

What Is the OIG Work Plan?

The OIG Work Plan is a public resource maintained by the Office of Inspector General. It outlines:

  • Current audits
  • Planned reviews
  • Evaluation projects
  • Compliance concerns
  • Areas receiving increased scrutiny

The Work Plan evolves throughout the year as new risks emerge and priorities change. That’s why reviewing it once a year isn’t enough.

Why Does the OIG Publish It?

The Work Plan serves several purposes. It helps:

  • Promote transparency
  • Inform healthcare organizations
  • Identify areas of concern
  • Encourage proactive compliance

In many ways, the OIG is telling healthcare organizations: “These are the areas we’re watching.” Practices that pay attention can often address vulnerabilities before they become larger problems.

How Often Should You Review the Work Plan?

One of the key recommendations is simple: Review the OIG Work Plan monthly.

Why monthly? Because the Work Plan is not static. New projects can be added throughout the year. Emerging technologies, billing trends, enforcement priorities, and healthcare risks can all influence what the OIG chooses to review.

Monthly reviews help ensure your compliance efforts stay aligned with current risks.

Not Every Project Applies to Your Practice

This is where many people become overwhelmed. They open the Work Plan and see dozens of audit topics. The good news is you don’t need to worry about all of them. Instead, ask:

  • Does this apply to our specialty?
  • Do we provide this service?
  • Do we bill these codes?
  • Could this affect our reimbursement?

Focus on the projects most relevant to your practice.

Turn OIG Priorities Into Internal Audits

One of the smartest ways to use the Work Plan is to build internal audit projects around relevant topics. For example, if the Work Plan highlights:

  • Telehealth billing
  • Modifier 25
  • Medical necessity
  • High-level E/M services

Then those topics may deserve additional review within your practice.

The goal isn’t to assume you’re doing something wrong. The goal is to verify that you’re doing things correctly.

Use the Work Plan to Guide Training

The Work Plan can also help shape your compliance education strategy. It is a planning resource. Instead of guessing what employees should learn, consider:

  • Current OIG priorities
  • Recent audit findings
  • Emerging billing risks
  • Documentation concerns

Training becomes far more effective when it’s tied to real-world risks.

In reality, practice managers, providers, coders, billers, and leadership teams can all benefit from understanding current audit priorities. The Work Plan becomes much more useful when it’s shared and discussed rather than simply filed away.

The goal is preparation—not fear.

Real Practice Example

A multi-specialty physician group began reviewing the OIG Work Plan during quarterly compliance meetings.

Initially, leadership assumed most projects wouldn’t apply to them. However, several topics involving telehealth, medical necessity, and E/M documentation directly affected their providers.

The practice conducted focused chart reviews and provider education sessions based on those topics.

Months later, when a payer review occurred involving one of the same areas, leadership felt far more prepared because they had already addressed many of the risks internally.

The Work Plan didn’t predict the audit. It helped them prepare for it.

Does appearing in the OIG Work Plan mean a service is being investigated for fraud?

No.

Many Work Plan projects are audits, evaluations, or reviews designed to assess program integrity and identify improvement opportunities.

The Work Plan identifies areas of interest—not necessarily evidence of wrongdoing. However, practices should still pay attention because those areas may receive increased scrutiny.

Your practice may not be using the OIG Work Plan effectively if:

  • Compliance reviews are reactive rather than proactive.
  • Internal audits are not based on current risks.
  • Training topics rarely change.
  • Leadership is unfamiliar with current OIG priorities.
  • Documentation reviews occur only after denials increase.
  • Compliance planning is based solely on past problems.

Turn the OIG Work Plan Into an Audit Readiness Tool

✅ Visit the OIG Work Plan website.

✅ Identify projects relevant to your specialty.

✅ Review your highest-risk services.

✅ Schedule one focused internal audit.

✅ Discuss findings during leadership meetings.

✅ Incorporate Work Plan topics into future training.

The Work Plan is most valuable when it drives action. Practices that monitor the Work Plan regularly are often better prepared for audits and enforcement trends.

Bottom Line

The OIG Work Plan is one of the most valuable compliance tools available to physician practices. By reviewing it regularly, practices can identify emerging risks, prioritize audits, focus training efforts, and strengthen compliance programs before problems occur. The most successful organizations don’t wait for audits—they use resources like the OIG Work Plan to prepare for them.

Key Takeaways

  • The OIG Work Plan identifies current and emerging audit priorities.
  • New projects can be added throughout the year.
  • Monthly reviews are generally recommended.
  • The Work Plan helps guide internal audits and compliance planning.
  • Not every project applies to every practice.
  • The goal is awareness, not panic.
  • The Work Plan can help practices proactively reduce risk.

Stay Ahead of OIG Priorities Throughout the Year

OIG priorities change as healthcare evolves, making ongoing education critical. Healthcare Training Leader’s All-Access Training Pass provides year-round access to expert-led education on OIG audit priorities, compliance programs, medical necessity, documentation, coding compliance, fraud prevention, telehealth billing, and payer audits.

Rather than reacting to enforcement trends after they affect your practice, your team can stay informed, prepared, and proactive throughout the year.

 

 

All Access Pass

Meet Your Expert

Hillary Stemple

JD
Partner, ARENTFOX SCHIFF LLP

Hillary focuses her practice on advising a wide range of health care practices on complex health care regulatory matters such as compliance with health care fraud and abuse laws, with an emphasis on the Anti-Kickback Statute, Stark Law, and the False Claims Act.

Hillary also counsels clients on all aspects of overpayment issues and making voluntary self-disclosures, including the drafting and submission of self-disclosures to the OIG Self-Disclosure Protocol and the CMS Self-Referral Disclosure Protocol.

She also regularly coordinates with the firm’s Government Relations group on federal advocacy efforts before Congress and the US Department of Health and Human Services on behalf of health care practices.

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