OIG to Begin Advance Care Planning Audits

The U.S. Department of Health & Human Services Office of the Inspector General (OIG) in its June report to Congress indicated that it was adding advance care planning to its work plan. 

The OIG Work Plan details the office’s projects for the current and future fiscal years, including audits and evaluations. An issue may come on the OIG’s radar for a number of reasons including legal requirements, requests from Congress or other agencies and the potential impact the work would have on the quality of care and potential cost savings.

The addition of advance care planning to the agency’s list of priorities was spurred by concerns about improper billing based on potentially faulty documentation of services. 


“In 2016, Medicare began paying for Advanced Care Planning (ACP), which is a face-to-face service through which a Medicare physician (or other qualified health care professional) and a patient discuss the patient’s wishes for health care if he or she becomes unable to make decisions about care. It allows Medicare beneficiaries to make important decisions, giving them control over the type of care they receive and when they receive it,” OIG said in its report. “Previous reviews have shown improper payments due to a lack of clinical documentation to support face-to-face services, clinical documentation of the time spent discussing ACP, or both. We plan to perform a nationwide audit to determine whether Medicare providers for ACP services complied with federal regulations.”

Studies show that advance care planning can reduce hospitalizations by as much as 26%, reduce health care costs, increase community-based palliative care and hospice utilization, as well as significantly increase the likelihood that care will be delivered in accordance with the patient’s wishes.

Despite the benefits of advance care planning, many patients don’t pursue it or pursue it too late. Only 14% of patients with serious illnesses have advance care plans. Patients who choose to receive palliative care are the most likely to have a plan.


In recent years, a cottage industry has risen up around advance care planning as an increasing number of stakeholders recognize its value, including state and federal agencies, payers and health care providers.

OIG plans to release a report on its advance care planning audit activities sometime during 2021.