| Course | HCR 363 Risk Management, Auditing and Monitoring for Health Care Compliance |
|---|---|
| Module | Module 8 |
| Paper type | Compliance audit plan |
| Length | About 752 words, 5 pages |
| Format | APA 7 student paper |
| School | Arizona State University |
| Program | BS in Health Care Compliance and Regulations |
| Updated | October 2026 |
Free sample paper for HCR 363 Module 8
Following the Government's Lead: A 2027 Audit Plan Built From OIG's Active Work Plan
Student Name
BS in Health Care Compliance and Regulations, Arizona State University
HCR 363: Risk Management, Auditing and Monitoring for Health Care Compliance
Instructor Name
Month Day, Year
Following the Government's Lead: A 2027 Audit Plan Built From OIG's Active Work Plan
Purpose
OIG publishes its Work Plan to show which areas its auditors and evaluators are reviewing. When OIG is examining a service an organization provides, that service is likely to draw scrutiny from contractors and investigators as well, so compliance programs use the Work Plan to decide what to audit before the government does (Office of Inspector General [OIG], 2023). This plan applies three active Work Plan items to Sonoran Ridge Health's hospitals, clinics and surgery center for calendar year 2027.
Screening the Work Plan
The active Work Plan lists projects across HHS. Items were screened with two questions: does Sonoran Ridge provide the service, and does it bill Medicare for it in volume? Projects about state grants, Medicare Advantage plans and agency oversight were excluded. Three provider-facing projects announced in 2026 passed the screen.
| Work Plan item | Announced | OIG project | Why it applies |
|---|---|---|---|
| E/M services on the same day as minor surgery with no modifier 25 | March 16, 2026 | OAS-26-04-028 | Clinic dermatology, orthopedics and podiatry perform minor procedures at E/M visits |
| Inpatient claims for neurostimulator implantation surgeries | March 16, 2026 | OAS-26-01-035 | Both hospitals implant spinal cord stimulators; prior authorization does not apply to inpatient cases |
| Medicare payments for selected expanded laboratory panels | June 11, 2026 | OAS-26-09-071 | Hospital labs and urgent care clinics run respiratory and gastrointestinal panels |
Audit 1: Same-Day E/M Services and Minor Procedures
OIG's project notes that Medicare generally includes an E/M service in the payment for a minor procedure performed the same day, and adds payment only when the visit was significant and distinct from the procedure, which the physician signals with modifier 25 (OIG, 2026a). OIG found payments for same-day E/M services without the modifier during 2023 through 2025. For Sonoran Ridge, the risk runs in both directions: E/M services billed without modifier 25 that should have been bundled, and modifier 25 appended to visits that were not separately identifiable.
Objective: determine whether same-day E/M services billed with minor procedures were separately identifiable and correctly coded. Scope: clinic claims from January 2025 to December 2026. Sample: 100 claims, stratified by specialty. Timing: first quarter of 2027. Owner: compliance auditing with an external coding reviewer.
Audit 2: Inpatient Neurostimulator Implantation
OIG explains that Medicare requires prior authorization for outpatient neurostimulator implantation but not for inpatient procedures, which may leave inpatient claims vulnerable to improper payment, and that earlier audits found improper payments for outpatient implants (OIG, 2026b). The audit will test whether inpatient admission was justified and whether coverage requirements, such as a successful trial stimulation where applicable, were documented.
Objective: determine whether inpatient neurostimulator implantation claims met Medicare coverage and inpatient admission requirements. Scope: all inpatient implant claims at both hospitals from 2024 to 2026. Sample: all claims, expected to be fewer than 60. Timing: second quarter of 2027. Owner: hospital utilization review with compliance.
Audit 3: Expanded Laboratory Panels
OIG notes that panels detecting six or more pathogens pay more than targeted panels of up to five, and that providers may be ordering expanded panels when a targeted panel would be enough. Medicare covers nothing that is not reasonable and necessary for diagnosis or treatment, and some contractors have local coverage determinations with specific requirements (OIG, 2026c).
Objective: determine whether expanded respiratory and gastrointestinal panels were medically necessary and met the applicable local coverage determination. Scope: hospital and clinic claims from 2025 and 2026. Sample: 80 claims. Timing: third quarter of 2027. Owner: laboratory director with compliance.
Priority, Reporting and Follow-Up
Findings from each audit will be reported to the compliance committee within 30 days of fieldwork, with root causes and corrective actions. Overpayments found along the way go to the refund team with the 60-day clock already running (42 C.F.R. § 401.305). A summary of all three audits will go to the board in the fourth quarter, along with recommendations for monitoring that will continue after the audits close.
| Audit | Exposure | Link to internal risks | Priority |
|---|---|---|---|
| Same-day E/M and modifier 25 | High volume, routine visits | Risk 1, unsupported E/M levels | First |
| Expanded laboratory panels | Moderate volume, higher payment | New risk not in the workbook | Second |
| Inpatient neurostimulators | Low volume, high payment per claim | Related to admission review | Third |
Conclusion
The OIG Work Plan tells a compliance program where federal reviewers are looking. Matching active items to the organization's own services, then ranking them against risks already identified, turns a government list into a focused, defensible audit plan for the year ahead.
References
Office of Inspector General. (2023). General compliance program guidance. U.S. Department of Health and Human Services. https://oig.hhs.gov/documents/compliance-guidance/1135/HHS-OIG-GCPG-2023.pdf
Office of Inspector General. (2026a). Evaluation and management services on same day as minor surgery with no modifier 25 (Work Plan project OAS-26-04-028). U.S. Department of Health and Human Services. https://oig.hhs.gov/reports/work-plan/browse-work-plan-projects/evaluation-and-management-services-on-same-day-as-minor-surgery-with-no-modifier-25/
Office of Inspector General. (2026b). Inpatient claims for neurostimulator implantation surgeries (Work Plan project OAS-26-01-035). U.S. Department of Health and Human Services. https://oig.hhs.gov/reports/work-plan/browse-work-plan-projects/inpatient-claims-for-neurostimulator-implantation-surgeries/
Office of Inspector General. (2026c). Medicare payments to providers for selected expanded laboratory panels (Work Plan project OAS-26-09-071). U.S. Department of Health and Human Services. https://oig.hhs.gov/reports/work-plan/browse-work-plan-projects/medicare-payments-to-providers-for-selected-expanded-laboratory-panels/
Reporting and returning of overpayments, 42 C.F.R. § 401.305 (2024).
Reading the HCR 363 Module 8 assignment instructions
Assignment 8 falls in Week 6 of HCR 363, the module on deciding when and to whom findings are reported and how corrective action plans are developed and monitored. The syllabus asks you to develop an audit plan using the information in OIG's active Work Plan, the list of audits and evaluations HHS's Office of Inspector General currently has under way. The Work Plan is public and searchable, and each item gives an announcement date, a project number and a short description of what OIG will examine and why. Your job is to find the items that apply to the course's organization of hospitals, clinics and a surgery center and turn them into audits the organization would run itself, with objectives, scope, samples, timing and owners. The plan feeds the final board presentation in Week 7, so write it as something leadership could approve.
How this HCR 363 Module 8 example is built
A purpose paragraph explains why compliance programs use the Work Plan. The screening section states the two questions used to choose items and shows the three that passed in a table with announcement dates, project numbers and reasons they apply. Each audit then gets its own section: what OIG said about the risk, cited to the Work Plan item, and the organization's own objective, scope, sample, timing and owner. One sampling choice is explained in a margin note. A priority table ranks the three audits by exposure and links each to the risks already found in the workbook, and a reporting paragraph sets timelines for the committee, refunds and the board. The conclusion restates how a government list becomes an internal plan.
Where the marks sit in the HCR 363 Module 8 rubric
Canvas grades the Work Plan audit plan out of 65. A strong audit plan uses current, active Work Plan items that genuinely match the organization's services, explains each item's risk accurately from OIG's description, sets audit objectives, scope, sample, timing and owners that fit the risk, prioritizes the audits with reasons and describes how findings will be reported and acted on, including the 60-day overpayment rule. Points are lost when items are outdated or irrelevant, such as Medicare Advantage plan audits for a provider system, when the plan copies OIG's text without adapting it, when audits have no scope or sample and when reporting is left out. Readers also look for links to the risks found earlier in the course, since the Work Plan should sharpen the risk assessment rather than replace it.
HCR 363 Module 8 help: mistakes that cost marks
Search the active Work Plan by provider type and filter out items about states, plans and agencies. Pick items your organization actually bills in volume. Read each item's objective carefully; it tells you what OIG thinks goes wrong. Write your own objective for each audit, then scope, sample, timing and owner. Explain any sampling choice. Rank the audits and say why. Add a reporting timeline with the 60-day rule. Connect at least one audit to a risk from your workbook. If you cannot find enough relevant items, the desk can help you search the Work Plan by issue area.
Write yours, or have the desk draft it
This paper is an original model document written by our desk, not a submitted student paper and not an official Arizona State University document. Read it for the moves, then write your own to the instructions in your classroom. If you want one built to your exact prompt and rubric, the first custom sample is free and arrives in 24 to 48 hours.
More HCR 363 and BS in Health Care Compliance and Regulations sample papers
- HCR 363 Module 1: Assignment 1: Risk Assessment Pre-Work
- HCR 363 Module 2: Assignment 2: Compliance Risk Assessment Survey
- HCR 363 Module 6: Assignment 6: Risk Root Cause Analysis (Five Whys)
- HCR 363 Module 7: Assignment 7: Auditing, Monitoring and Mitigation Planning
- HCR 262 Module 2: Writing Assignment 2: Professional Misconduct Mock Investigation
- HCR 264 Module 5: Root Cause Analysis: OSHA Incident Report and Five Whys
- HCR 350 Module 4: Paper 4: Integrating Research Compliance Into the Corporate Compliance Program
HCR 363 Module 8 questions, answered
Where can I find a free HCR 363 Module 8 sample paper?
This page has a full Assignment 8 sample: a 2027 audit plan built from three active OIG Work Plan items for a hospital and clinic system.
What is the OIG Work Plan?
A public list of the audits and evaluations HHS's Office of Inspector General has planned or under way, updated as projects are added.
How do compliance programs use the OIG Work Plan?
They match active items to their own services and audit those areas before government reviewers do.
What should each audit in an audit plan include?
An objective, scope, sample, timing, owner and how findings will be reported and corrected.
What is modifier 25 used for?
It tells Medicare that a visit billed alongside a minor procedure was a significant, distinct service, not just the routine evaluation the procedure already pays for.