Recently, the Office of Inspector General (“OIG”) released a Work Plan to identify the reviews and investigations that the OIG intends to pursue in 2013. Notwithstanding the federal government’s initiatives to encourage the adoption of Electronic Health Record (“EHR”), EHR systems will be a focus of several OIG reviews. The OIG’s goal is to protect the integrity of the Medicare program and evaluate the Department of Health and Human Resources (DHHS) programs. Ultimately, the OIG Work Plan highlights areas where the government enforcement actions are historically focused and areas that providers should address through their compliance programs.
In 2009 the American Recovery and Reinvestment Act (“Stimulus Act”), created the DHHS EHR financial incentive program. This program provided financial incentives to healthcare providers, including hospitals and physicians, that adopt, implement and meaningfully use certified EHRs. Over $20 Billion was dedicated to