decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Voluntary Disclosure Program / After Disclosure - What OIG Expects / Self-Assessment Guidelines
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Article Overview
This article explains the general framework OIG expects when a health care provider performs a self-assessment after making a disclosure. It is relevant to compliance, auditing, and reimbursement integrity teams that need to understand what a review plan should cover, how sampling and estimation are approached at a high level, and what documentation is expected in the final submission.
Why This Topic Matters
Accurate self-assessment and documentation can affect how OIG reviews a disclosed matter and evaluates potential program losses or related liability. This guidance helps providers and auditors understand the scope of information OIG expects in the work plan and final report.
Article Sections
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Approach
Describes the broad review approaches that may be used for the internal financial assessment and the factors that influence the choice between them.
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Basic information
Summarizes the overall work plan expectations, OIG involvement, and the types of topics the plan should address.
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Review objective
Addresses the need to define the purpose of the review and the procedures used to carry it out.
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Review population
Explains how the relevant population should be identified and described in the review plan.
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Sources of data
Covers the types of source materials and reference standards that should support the review.
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Personnel qualifications
Describes the personnel and qualifications that should be identified for the self-assessment team.
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Sample elements
Introduces the sampling-related content that should be included when the assessment uses a sample.
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Sampling unit
Defines the unit of analysis used in the sampling plan.
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Sampling frame
Addresses how the sample source universe is defined and documented.
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Sample size
Covers how the sample size is planned and documented at a general level.
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Random numbers
Discusses how random selection is documented and identifies a recommended statistical tool.
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Sample design
Outlines the general expectations for the sampling design and possible alternative approaches.
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Estimate of review time per sample item
Notes that the plan should estimate the time and effort associated with reviewing each sampled item.
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Characteristics measured by the sample
Describes how the plan should define the items or attributes being evaluated in the sample.
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Missing sample items
Covers documentation of how missing items are handled in the sampling process.
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Other evidence
Addresses the role of corroborating information alongside sample results.
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Estimation methodology
Explains the overall estimation approach and reporting expectations for monetary loss calculations.
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Reporting results
Summarizes how the review findings should be presented in the final report.
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Certification
Describes the final certification expected from the provider or authorized representative upon completion of the assessment.
What You Will Learn
- How OIG expects a post-disclosure self-assessment to be organized
- What a review work plan should generally include
- How sampling-related documentation is structured at a high level
- What types of estimation and reporting topics are addressed
- What certification is expected at the end of the process
Who Should Read This
- Health care providers
- Compliance officers
- Auditors
- Billing and reimbursement teams
- Healthcare consultants
- Statisticians supporting healthcare reviews
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