The federal Office of Inspector General (OIG) recently released a Work Plan that lays out in detail its plans for reviewing, among other things, the HITECH incentive program.

But, only half tongue-in-cheek, we’d like to suggest the OIG expand its purview a bit.

As this summary explains it, “the OIG will be focused on determining whether the EHR meaningful use payments were correctly paid and whether EHR systems are susceptible to causing fraud in the Medicare payment system. In addition, the OIG intends to evaluate how the enhanced penalties and obligations of HIPAA are enforced by the Office of Civil Rights (“OCR”) as well as providers’ compliance with the breach notification rules created by HITECH.

“Specifically, the OIG intends to ‘review Medicare incentive payment data from 2011 to identify payments to providers that should not have received incentive payments (e.g., those not meeting selected meaningful use criteria).’ Further for the Medicaid program, the OIG will review whether the Medicaid financial incentives to ‘providers to purchase, implement, and operate EHR technology were claimed in accordance with Medicaid requirements’. Therefore, the same providers who proactively engaged in this program may be required to respond to government inquiries and audits to ensure the funding was proper.”

We can appreciate the desire to ensure the proper functioning of the incentive program, but in the interest of ensuring the overall efficiency of the digital transition we’d suggest OIG take a look at this announcement as well.

Apparently, “the Indian Health Service is offering Web access for patients to a portion of their medical and administrative information it holds in the IHIS Medical, Health and Billing Records system as part of a personal health records (PHR) system it is developing.”

The article quotes an announcement in the Federal Register which says “initially, tribal patients will have access to view and print portions of their official IHS electronic health record (EHR) via the Internet,” while “future IHS PHR functionality will include tools patients can use to improve their health and increase their knowledge about their health conditions; increase communication with their care providers through secure electronic messaging; request online prescription refills and view upcoming appointments; and enter their own medical information in a self-entered health information section through a secure and private health space.”

Our request of the OIG, then, is to see if the IHS system bears resemblance to, or is perhaps even identical to, the system used by the Veterans Administration, among other federal agencies with healthcare responsibilities.

And if not, why not?

Photo courtesy of Images_of_Money via Creative Commons