OIG Work Plan Monthly Updates

von Briesen continues to monitor the United States Department of Health and Human Services, Office of Inspector General (the “OIG”) Work Plan to provide insight into emerging legal trends in health care. Health organizations are advised to use the Work Plan to identify the OIG’s areas of interest and enforcement priorities, and to review and update policies and procedures accordingly.

This Legal Update summarizes some of the significant OIG Work Plan updates released for November 2018, December 2018, January 2019, and February 2019.

CMS mandates that nursing facilities provide sufficient licensed nursing staff 24-hours a day and have a registered nurse present for at least 8 consecutive hours a day, 7 days a week. Staffing data is submitted to CMS’s Payroll-Based Journal. CMS uses this data to analyze staffing patterns and to populate staffing information in the Nursing Home Compare website. The OIG will produce two reports about this data. The first report will be a data brief that describes nursing staffing levels reported by facilities. The second report will examine the efficacy of CMS’s efforts to ensure the self-report data’s accuracy and improve quality of care. Long term care providers should review their self-reported staffing information to ensure its accuracy.