OIG Work Plan 2026: What's Changed and How It Affects Your Practice
The OIG releases its Work Plan annually, signaling where federal enforcement attention will focus. Here's what the 2026 Work Plan means for small and mid-size medical practices.
Every year, the Office of Inspector General (OIG) publishes its Work Plan — a forward-looking document that identifies areas it intends to review, audit, and investigate. For healthcare providers, the Work Plan is one of the most actionable compliance intelligence documents available. Understanding it helps your practice get ahead of enforcement attention before it arrives.
Key 2026 Work Plan Areas Affecting Small Practices
Medicare Billing Accuracy
Evaluation and Management (E&M) billing continues to be a top OIG priority. The OIG is reviewing whether E&M services billed to Medicare are supported by medical necessity documentation and whether the level of service billed matches the record. Small practices with high-volume E&M billing should audit a sample of their claims.
Telehealth Fraud and Compliance
The OIG continues scrutiny of telehealth billing practices — particularly for services that may not meet Medicare coverage requirements for behavioral health, physical therapy, and chronic care management.
Provider Enrollment Compliance
The OIG is reviewing CMS's oversight of provider enrollment — whether enrolled providers meet all eligibility requirements. Practices should ensure all billing providers are properly enrolled and that enrollment information is current.
How to use the Work Plan: Map each relevant Work Plan item to your practice's risk exposure. Address gaps before an OIG reviewer does.
The OIG's Seven-Element Compliance Program Framework
- Written policies and procedures
- Compliance officer and compliance committee
- Effective training and education
- Effective lines of communication
- Internal monitoring and auditing
- Enforcement of standards and disciplinary guidelines
- Responding promptly to detected offenses
Building a Work Plan Response Process
- Download the current OIG Work Plan at oig.hhs.gov
- Identify all items relevant to your practice's service lines
- Assess your documentation and controls against each relevant item
- Document your risk assessment and remediation actions
- Track remediation to completion
- Repeat quarterly as the Work Plan is updated
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