Corinne Nierzwicki
Executive Production Editor
Loyola University Chicago School of Law, JD 2018

This summer I had the opportunity to intern with the Office of Inspector General for the U.S. Department of Health & Human Services (OIG) in Washington, DC. I thoroughly enjoyed my time with OIG, and I learned a great deal about health care fraud, waste, and abuse. In spending my summer with OIG, I had a glimpse into the powerful regulatory bodies that protect the health care market from abuse. As I move forward with my career in regulatory work, I will take with me the invaluable experiences and skills from my internship.

My Introduction to OIG

I first learned about OIG in Loyola’s Health Care Compliance course, taught by the Editor-in-Chief of the Journal of Regulatory Compliance, Ryan Meade. In class we learned that OIG, in conjunction with the Department of Justice (DOJ), oversees the enforcement of health care fraud, waste, and abuse laws for Federal health care programs, including Medicare and Medicaid. OIG consists of auditors, investigators, and attorneys all across the U.S. who are investigating fraud and litigating abuses of the Federal health care programs. Importantly, OIG has the authority to exclude providers and vendors who commit fraud from participating in Federal health care programs. OIG’s work is important because those intent on defrauding Federal health care programs cost taxpayers billions of dollars, while putting beneficiaries’ health and welfare at risk.

Certainly, our class highlighted the importance of OIG and eliminating fraud, waste, and abuse in health care. Indeed, OIG has been involved in significant enforcement activities this year. In July, OIG, DOJ, and other Federal agencies announced the largest Federal health care fraud enforcement action in U.S. history. During the same period, the U.S. Attorney’s Office for the Northern District of Illinois created the Health Care Fraud Unit to fight criminal health care fraud in its jurisdiction. Various fraud enforcement convictions and settlements this year have amounted to hundreds of millions of dollars. In March, OIG and the Health Care Compliance Association (HCCA) emphasized the importance of maintaining effective compliance programs to comply with Federal health care fraud, waste, and abuse law in jointly releasing the Measuring Compliance Program Effectiveness: A Resource Guide. It is clear that health care entities need to implement and maintain effective compliance programs to prevent health care fraud, waste, and abuse as the consequences for noncompliance are significant.

My Experiences in My Internship

With the discussion from class fresh in my mind, I jumped at the opportunity to apply to intern with the Office of Counsel to the Inspector General and was delighted when I was offered the opportunity to work with OIG in DC for the summer.

As an intern, I conducted research and drafted memoranda, briefs, and correspondence. I dealt first-hand with issues ranging from corporate integrity agreement monitoring to Federal health care exclusion appeals, delving into the Social Security Act, the Civil Monetary Penalties Law, the Anti-Kickback Statute, the False Claims Act, the Emergency Medical Treatment and Active Labor Act (EMTALA), the Medicare Access and CHIP Reauthorization Act (MACRA), and the 21st Century Cures Act.  In particular, I enjoyed the practical, hands-on work of analyzing EMTALA case files that were recommended to OIG from the Centers for Medicare and Medicaid Services (CMS). I had to diligently read and consider hundreds of pages of medical records and then draft recommendation memoranda to my supervising attorneys about whether OIG should pursue civil monetary penalties in the case. I truly felt as though my work moved the needle for the people and health care providers involved.

In addition to the practical experience I gained at OIG, it was rewarding to work for an organization that had such a positive mission. OIG’s primary duty is to protect the beneficiaries of Federal health care programs along with protecting the Federal health care funds. I originally was drawn to health law and health care compliance because I wanted to help improve patient care; protecting patients is such a large part of OIG’s work. In addition to protecting patients, OIG’s efforts to protect Federal health care funds are also important. According to the Congressional Budget Office, Federal health care programs amount to billions of dollars in the annual Federal budget, and the costs continue to rise. Although many economic factors contribute to the high costs of care, fraud, waste, and abuse costs the Federal government approximately 100 billion dollars annually. OIG plays an integral role curtailing the wasting of Federal health care funds. It was great to have an opportunity to not only learn but to contribute to an organization that does such important work.

In addition to the value of my internship, OIG is staffed with wonderful people that make for a great office culture. The attorneys and the other interns that I worked with truly made me feel a part of the team. Being in Washington for the summer also provided a great opportunity to explore the museums and monuments in Washington. My favorite thing that I saw was Supreme Court Building; it was awe-inspiring to stand in such an important edifice in our American legal system. (Did you know that there is a basketball court located above the courtroom of the Supreme Court? It’s the highest court in the land!) All said and done, I took great pleasure in the people and the sites in DC; they were an added bonus to the wonderful learning opportunity that was the OIG internship.

My summer was rewarding, and I learned a great deal of substantive law and practical skills. I would recommend that other law students interested in health law and health care compliance to apply to similar opportunities with OIG. Personally, I cannot wait to apply my experiences and skills gained from my internship as I begin applying for post-graduation jobs.

NOTICE: Views expressed in this post are not to be construed as statements on behalf of the Office of Inspector General for the U.S. Department of Health and Human Services.