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OIG Work Plan Compliance Guides

Practitioner-level
compliance
references.

OIG Work Plan guides written for administrators and compliance officers who read regulatory documents, not just summaries of them. Verbatim OIG language, specific dollar exposure, and concrete corrective actions — organized as professional references, not checklists.

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OIG Work Plan — Mental Health Live
OIG Work Plan — Home Health Live
OIG Work Plan — Primary Care Live
OIG Work Plan — Hospice Live
OIG Work Plan — Medspa Coming Soon
2026 Compliance Guides

OIG Work Plan guides
built for practitioners.

Each guide draws verbatim OIG Work Plan language, maps active audit items to specific billing codes and documentation requirements, and provides concrete corrective action language. These are compliance program reference documents — not executive summaries.

OIG Work Plan 2026 · Pillar IILive

Mental Health Compliance Guide

Independent behavioral health, psychology, and psychiatric practices billing Medicare/Medicaid

Covers the full OIG Work Plan audit surface for mental health providers — psychotherapy session documentation, E/M leveling in psychiatric settings, telehealth billing post-PHE, and the documentation requirements that generate the highest overpayment rates in behavioral health claims.

  • 90837 and 90834 documentation standards and common deficiencies
  • Telehealth billing compliance — post-PHE audit targets
  • E/M in psychiatric settings — MDM vs. time-based billing
  • Modifier 25 exposure in behavioral health same-day billing
  • OIG overpayment data and dollar exposure estimates
  • Corrective action language for compliance program integration
OIG Work Plan 2026 · Pillar IILive

Home Health Compliance Guide

Independent and small-chain home health agencies operating under Palmetto JM HHH

HHA-specific OIG audit priorities for 2026 — face-to-face encounter documentation, OASIS-E2 transition compliance, PDGM coding integrity, and the Reason Code 56900 denial pattern that accounts for nearly half of all Palmetto HHA denials. Written for HHA administrators and compliance officers.

  • F2F encounter — 42 CFR 424.22 compliance and documentation standards
  • OASIS-E2 — A1255, A1110, ROC timepoint changes effective April 2026
  • PDGM HIPPS coding integrity and case-mix group risk
  • Reason Code 56900 — prevention and ADR response protocol
  • Palmetto JM HHH TPE patterns and active edit targets
  • OIG overpayment data with corrective action templates
OIG Work Plan 2026 · Pillar IILive

Primary Care Compliance Guide

Solo and small-group primary care, DPC, and internal medicine practices billing Medicare

The highest-density OIG audit surface of any specialty. E/M level distribution, AWV documentation, CCM billing, modifier 25 same-day frequency, and split/shared visit billing under the 2024 rule revision. Includes a section on the voluntary repayment framework and self-disclosure positioning for overcoding findings.

  • E/M 99202–99215 — level distribution benchmarks and overcoding risk
  • AWV (G0438/G0439) — documentation requirements and denial patterns
  • CCM (99490, 99491) — enrollment gap analysis and billing compliance
  • Modifier 25 — OIG audit data and same-day frequency thresholds
  • Split/shared visit — 2024 rule application and documentation
  • Voluntary repayment framework and self-disclosure language
OIG Work Plan 2026 · Pillar IILive

Hospice Compliance Guide

Independent hospice operators — especially those operating under Palmetto JM HHH or in PPEO states

The 2026 OIG Work Plan items most directly affecting independent hospice operators: GIP documentation and level-of-care appropriateness, aggregate cap exposure mechanics, election statement and Addendum compliance, HOPE implementation, and the PPEO prepayment review posture. Written against 42 CFR Part 418 and Palmetto LCD L38655.

  • GIP — documentation requirements and length-of-stay audit risk
  • Aggregate cap — FY 2026 mechanics ($35,361.44/beneficiary) and exposure modeling
  • Election statement and Addendum — post-FY 2020 compliance requirements
  • HOPE — SFV and HUV-1/HUV-2 timing compliance since October 2025
  • PPEO — prepayment review posture and documentation standards
  • Palmetto JM HHH TPE targets: Bene Sharing, Long-LOS, RHC, F2F
OIG Work Plan 2026 · Pillar IIComing Soon

Medspa Compliance Guide

Medical spas and aesthetic practices billing any Medicare-reimbursable services

The medspa compliance landscape is unusually complex: LegitScript certification, GCMB Nurse Protocol Agreement requirements under O.C.G.A. § 43-34-25, Cosmetic Laser Services Act compliance, and OIG audit exposure on any Medicare-reimbursable services billed alongside aesthetic procedures. This guide covers the full intersection. In production — email hello@prognosisconsulting.com to be notified at launch.

  • Georgia-specific: GCMB Nurse Protocol Agreement and Delegation requirements
  • Cosmetic Laser Services Act (§§ 43-34-240–248) compliance framework
  • Medicare-reimbursable services audit exposure in aesthetic settings
  • LegitScript certification and payment processor compliance
  • Corporate practice of medicine doctrine — Georgia application
What Makes These Different

Not summaries.
Reference documents.

01
Verbatim OIG Language

Drawn Directly From the Work Plan

Every audit item is quoted from the OIG Work Plan using the exact language the OIG uses — not a paraphrase. When an auditor cites a Work Plan item in a findings letter, you'll recognize the language because you've already read it in the guide.

02
Dollar Exposure

Overpayment Data per Audit Item

Where OIG prior audit reports include overpayment rates or dollar amounts, those figures are incorporated. A compliance officer who can attach a dollar figure to a risk item gets a board conversation. A compliance officer with a checklist does not.

03
Corrective Action

Ready-to-Use Policy Language

Each audit item includes a corrective action section with specific policy and procedure language that can be adapted directly into a compliance program. The guides are designed to reduce the gap between "we identified a gap" and "we fixed it."

04
Jurisdiction-Specific

Palmetto GBA JM HHH Positions

The post-acute guides (hospice, home health) incorporate Palmetto GBA JM HHH-specific positions, LCD references, and TPE edit patterns. National OIG guidance is the floor; what Palmetto is actually denying in Georgia is the ceiling.

05
Institutional Voice

Physician-Peer Reference Format

Formatted as a compliance officer or administrator would write an internal reference document — not a vendor white paper. No marketing language, no upsell in the footnotes. The guide is the product.

06
2026 Current

Aligned to the Active Work Plan

Benchmarked against the OIG's continuously updated Work Plan as of early 2026 — not a prior year's edition. Where the Work Plan has been updated since the guide was written, a revision is issued.

From Guide to Engagement

The guide identifies
the risk. We quantify it.

Every guide includes a soft pathway to the consulting engagement that validates its findings at the claims level. A guide tells you what to look for; an audit tells you what's actually there. Most guide buyers who have the relevant exposure schedule an engagement within 60 days.

If you read the guide and recognized something specific — a documentation pattern, a billing frequency, a workflow gap — that's the signal to schedule a discovery call. We can scope the right engagement from there.

Schedule a Discovery Call →
Stay Current

New guides and resources
as the Work Plan moves.

The OIG Work Plan updates continuously. New guides are added as we complete them — Medspa is next in queue, followed by SNF and staffing agency editions. Follow us on Gumroad to be notified at launch, or email us to be added to a specific guide's notification list.