Kusserow on Compliance: OIG response plan—four goals for the COVID-19 Crisis

The HHS Office of Inspector General (OIG) has identified four goals to respond to the COVID-19 Pandemic: protecting people, protecting funds, protecting infrastructure, and promoting effectiveness. The OIG set out its framework in the OIG Strategic Plan: Oversight of COVID-19 Response and Recovery.

PROTECT PEOPLE. The OIG plans for this goal include to: (1) issue guidance on its administrative fraud enforcement authorities related to delivering needed patient care; (2) conduct rapid-cycle reviews of conditions affecting HHS beneficiaries or health care providers; (3) inform/support response efforts; (4) help ensure continuity of HHS operations during the public health emergency; (5) identify and investigate fraud and scams that endanger HHS beneficiaries and the public; (6) alert the public to fraud schemes related to COVID-19; and (7) assess the impacts of HHS programs on the health and safety in the acquisition, management, and distribution of COVID-19 tests and vaccine and treatment research and development.

PROTECT FUNDS. HHS was appropriated $251 billion for COVID-19 response and recovery—to prevent, prepare for, and respond to coronavirus, along with funds from other appropriations. The OIG plans for this  goal include: (1) reviewing of oversight, management, and internal controls for awarding, disbursement, and use of funds; (2) assessing whether recipients met requirements; (3) mitigating major risks that cut across program and agency boundaries; (4) ensuring that intended purposes of funds granted are being used properly; (5) identifying and investigating suspected fraud and exercising OIG’s administrative enforcement authorities; (6) identifying program integrity vulnerabilities and recommend safeguards; and (7) providing alerts to potential fraud risks or schemes to steal funds.

PROTECT INFRASTRUCTURE. Objectives for this goal include: (1) protecting the security and integrity of IT systems and health technology; (2) identifying IT vulnerabilities and incidents, mitigating threats, and restoring IT services; and (3) focusing on identifying and investigating cybersecurity vulnerabilities related to COVID-19 response.

PROMOTE EFFECTIVENESS. The OIG’s plans for this goal include: (1) focusing on COVID-19 efforts to identify successful practices and lessons learned from the emergency preparedness and response; (2) reviewing pandemic preparedness planning to identify how preparedness funding was spent; and (3) assessing COVID-19 impact on HHS programs and beneficiaries, including expanded telehealth in Medicare.


Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

Connect with Richard Kusserow on LinkedIn.

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