OIG Work Plan 2026: Compliance Priorities Every Medical Coder Must Monitor
OIG’s Q1 2026 Work Plan and new MA compliance guidance put HCC coding and documentation under fresh scrutiny — here is what every coder needs to know.
The Office of Inspector General’s Q1 2026 Work Plan and new Medicare Advantage compliance guidance put HCC coding and documentation under fresh scrutiny. Here is what every medical coder needs to know.
The Compliance Priorities Driving 2026 Audits
OIG identified several focus areas for 2026 that will reshape audit risk for hospital and physician coding teams: HCC capture accuracy under CMS-HCC V28, Medicare Advantage risk adjustment data validation (RADV), telehealth E/M documentation, and split/shared service billing in inpatient settings.
What HCC Coders Should Do
The V28 model is sharper than V24. Diagnoses must be supported by face-to-face encounter documentation in the year billed, with MEAT criteria (Monitor, Evaluate, Assess, Treat) clearly satisfied. RADV samples in 2026 will look for documentation gaps that V24 forgave.
Telehealth E/M and Split/Shared Services
Audits target whether documentation matches the level coded. With the 2026 changes to split/shared rules, the substantive portion of the visit must be clearly identified in the note, and the role of each provider documented.
What to Do Now
- Run an internal HCC audit on V28-affected codes
- Review telehealth E/M sample for documentation quality
- Update split/shared service templates and educate providers
- Build an OIG Work Plan tracking calendar for the year