The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) is the largest inspector general's office in the federal government and is tasked with providing oversight to more than 100 federal health and welfare programs, including Medicare and Medicaid. OIG plays a critical role in preventing and detecting healthcare fraud and abuse. OIG guidance is essential reading for everyone in the healthcare industry.
The second Trump administration brought significant changes to OIG, including the departure of several key personnel. On January 24, 2025, HHS Inspector General Christi Grimm was dismissed along with the inspectors general (IGs) from 16 other departments. Over the next several months, OIG saw the departure of a number of other key staff with decades of experience, including the Chief Counsel to the Inspector General, the Chief Medical Officer, the Deputy Inspector General for Audit Services, the Assistant Inspector General for Legal Affairs, and others. The new Inspector General – Thomas "March" Bell – was nominated in March but was not confirmed by the Senate until December 18, 2025, and was sworn in on December 22, 2025. As we move into 2026, we will be watching to see how Inspector General Bell seeks to influence OIG's priorities.
While it is difficult to fully appreciate the effects of these personnel changes on the overall operations of OIG, we saw relatively few major announcements in 2025. OIG did not issue any Special Fraud Alerts, Special Advisory Bulletins, or new Frequently Asked Questions (FAQs) in 2025. There was, however, an Enforcement Alert on Information Blocking that was jointly issued on September 4, 2025, by OIG and the Office of the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology. Despite an initial forecast that OIG would issue two new Industry Segment-Specific Compliance Program Guidance (ICPG) documents, none were issued in 2025. OIG issued 12 advisory opinions in 2025, which continued a downward trend over the past several years. For their parts, OIG's Office of Audit Services and Office of Evaluation and Inspection continued to issue reports on their work.
Despite the drop in formal guidance, OIG continued to be actively involved in enforcement actions throughout the country. We saw this through the Civil Monetary Penalty (CMP) and Affirmative Exclusion actions posted on OIG's website, as well as through mentions of OIG cooperation in nearly every Department of Justice (DOJ) press release about healthcare fraud enforcement actions. OIG continued to focus on core priorities such as medically unnecessary services, improper billing, and Emergency Medical Treatment and Labor Act (EMTALA) violations. OIG also continued its efforts to investigate misuse of pandemic-era relief funds. In conjunction with False Claims Act (FCA) settlements, OIG entered into 15 Corporate Integrity Agreements (CIAs) in 2025, down slightly from prior years. OIG also identified three entities that refused to enter into CIAs and were placed on OIG's Heightened Scrutiny list.
Bass, Berry & Sims is pleased to share this fourth annual HHS-OIG Year in Review (HHS-OIG YIR). Our goal is not to offer an exhaustive examination of every guidance document published by OIG in 2025. Instead, we use our team's decades of collective experience analyzing fraud and abuse issues both inside and outside OIG to focus on the items we think are most significant and/or most useful to the healthcare industry.
In this year's HHS-OIG YIR, we discuss the following topics:
- Joint FCA Working Group Announcement
- Update on CIAs and OIG Heightened Scrutiny List
- Advisory Opinions
- Significant Self-Disclosure Protocol (SDP) Settlements
- Medicare Advantage Industry Segment-Specific Compliance Program Guidance
We hope that this year's HHS-OIG YIR helps you to better understand how OIG frames and analyzes fraud and abuse issues so you can identify and manage risks in today's complex healthcare regulatory environment.