Each month, we are pleased to share the most recent additions to the HHS Office of Inspector General (OIG) Work Plan items. Starting in June 2017 – OIG has been updating their Work Plan monthly with any new changes to the active list. Let’s take a look at the new updates from this month.
What is the OIG Work Plan?
The HHS OIG Work Plan sets forth various projects that OIG plans to undertake during the fiscal year (FY) and beyond.
Projects listed in the Work Plan span HHS’s operating divisions, including the following:
- Centers for Medicare & Medicaid Services (CMS)
- Public health agencies such as the Centers for Disease Control and Prevention (CDC)
- National Institutes of Health (NIH)
- Administration for Children and Families (ACF)
- Administration for Community Living (ACL)
- Various state and local governments – evaluating the use of federal funds as well as the administration of HHS
*Some of the projects described in the Work Plan are statutorily required.
The August agenda includes 12 new items from HHS Office of Inspector General (OIG). Let’s walk through this latest release so you can address it within your compliance program, if applicable.
- Opioids in Medicaid: Review of Extreme Use and Overprescribing in the Appalachian Region
- Nursing Homes: CMS Oversight of State Survey Agencies
- Use of Telehealth to Provide Behavioral Health Services in Medicaid Managed Care
- Medicaid Assisted Living Services
- Medicare Part B Services to Medicare Beneficiaries Residing in Nursing Homes During Non-Part A Stays
Opioids in Medicaid: Review of Extreme Use and Overprescribing in the Appalachian Region
The opioid epidemic in Appalachia continues to present unique challenges and problems to solve for local and national health agencies and law enforcement. HHS OIG continues to investigate and review the devastating effects of provider overprescribing and opioid usage in Appalachia. During 2017, the number of overdose deaths involving opioids reached 48,000 nationwide and was 72 percent higher in the region as compared to other parts of the country.
To further uncover some of the misuse and prescribers involved in these tragedies, HHS OIG will continue to evaluate Medicaid and Medicare Part D in Appalachia. Investigators hope to find patterns of pharmacy or doctor shopping and prescriber records associated with beneficiaries.
Nursing Homes: CMS Oversight of State Survey Agencies
State survey agencies (SAs) are contracted to work with the Centers for Medicare and Medicaid Services (CMS) in determining nursing home compliance with Medicare requirements. Various OIG reports found that SAs did not perform services efficiently or thoroughly in verifying corrected deficiencies or complaints.
In an effort to improve state survey agency performance and CMS oversight, HHS OIG will be interviewing and reviewing CMS monitoring efforts, as well as identifying any barriers for progress.
Use of Telehealth to Provide Behavioral Health Services in Medicaid Managed Care
HHS OIG describes telehealth as, “the use of telecommunications and information technology to provide access to health assessment, diagnosis, intervention, consultation, supervision, and information across distance”. As Telehealth becomes more prominent in the U.S. healthcare system, there is a great need to ensure that compliance standards are met and fraudulent activity is reduced given federal and state requirements.
Each state is currently incorporating telehealth services in Medicaid coverage, but the information is limited about how states are using telehealth to provide behavioral health services to Medicaid managed care members. HHS OIG will be taking a look at how each state and Managed Care Organizations (MCOs) are using telehealth to reduce spending and increase access.
Medicaid Assisted Living Services
A 2018 report from the Government Accountability Office identified that improvements must be made in the oversight of each state’s administration of Medicaid assisted living services. HHS OIG will investigate providers’ delivery of quality care to beneficiaries and properly claimed Medicaid reimbursement with federal and state requirements for Medicaid Assisted Living Services.
Medicare Part B Services to Medicare Beneficiaries Residing in Nursing Homes During Non-Part A Stays
Most Medicare Part B services for beneficiaries residing in nursing homes do not have consolidated billing, meaning many times each provider will submit a claim to Medicare. For many years, HHS OIG has identified Medicare Part B payment issues for beneficiaries residing in nursing homes. Because of a lack of nursing home awareness of services claimed from each provider, the opportunities for unnecessary, excessive, or fraudulent billing in Part B payment is prevalent.
The Office of Inspector General (OIG) will determine if nursing homes (NHs) have effective compliance programs and controls in place for Part B payments and are delivering proper care to residents for each claim.
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Written by Michael Rosen, Esq.
Michael brings over 20 years of experience founding and leading risk mitigation businesses, receiving numerous accolades such as Inc. Magazine’s Inc. 500 Award and Nashville Chamber of Commerce Small Business of the Year.