Each month, we are pleased to share the most recent additions to the HHS Office of Inspector General (OIG) Work Plan items. HHS OIG updates its Work Plan monthly with 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 9 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. 

  1. Audit of Obligations and Expenditures Made From Biomedical Advanced Research and Development Authority FY 2018 and FY 2019 Appropriations
  2. Audit of the Assistant Secretary for Preparedness and Response Biomedical Advanced Research and Development Authority’s Awarding of Research and Development Contracts for FY 2017 through FY 2020
  3. Rates of Estimated Payments From Chart Reviews and Health Risk Assessments Across Medicare Advantage Organizations
  4. Accuracy of Nursing Home Compare Website’s Reported Health, Fire Safety, and Emergency Preparedness Deficiencies
  5. Audit of the Distribution of Supplies From Indian Health Service’s National Supply Service Center in Response to COVID-19
  6. Audit of Foundational Cybersecurity Controls for the U.S. Healthcare COVID-19 Portal and Protect.HHS.gov
  7. Infection Control and Emergency Preparedness at Dialysis Centers During the COVID-19 Pandemic
  8. Audit of CARES Act Provider Relief Funds—General and Targeted Distributions to Hospitals

Audit of Obligations and Expenditures Made From Biomedical Advanced Research and Development Authority FY 2018 and FY 2019 Appropriations

As a leader of the Nation’s medical and public health preparedness, The Biomedical Advanced Research and Development Authority (BARDA) safeguards against influenza and emerging infectious diseases. 

In order to determine whether congressional FY 2018 and FY 2019 appropriations, given to support BARDA’s advanced research and development, were appropriately used (and according to section 319L of the Public Health Service Act and other administrative expenses), the OIG intends to audit the obligations and expenditures.


Audit of the Assistant Secretary for Preparedness and Response Biomedical Advanced Research and Development Authority’s Awarding of Research and Development Contracts for FY 2017 through FY 2020

As a leader of the Nation’s medical and public health preparedness, The Biomedical Advanced Research and Development Authority (BARDA) safeguards against influenza and emerging infectious diseases. 

To support BARDA’s advanced research and development (agreeable to section 319L of the Public Health Service Act), congressional FY appropriations are given under the Assistant Secretary for Preparedness and Response (ASPR) Next and BARDA Division of Research, Innovation, and Ventures (DRIVE) programs.

The OIG will determine whether ASPR complied with Federal requirements when awarding contracts with BARDA FY 2017 through FY 2020 appropriations, while also correctly using ASPR Next and DRIVE programs.


Rates of Estimated Payments From Chart Reviews and Health Risk Assessments Across Medicare Advantage Organizations

The Medicare Advantage (MA) program, an “all in one” alternative to Original Medicare, provided coverage to 23 million beneficiaries in 2019 at the cost of $264 billion. 

CMS risk-adjusts these payments by using beneficiaries’ diagnoses to pay higher capitated payments (fixed, pre-arranged monthly payments received by a physician, clinic, or hospital per patient enrolled in a health plan), to MA organizations (MAOs) for beneficiaries expected to have more significant health care needs. 

This payment policy may create financial incentives for MAOs to misrepresent beneficiaries’ health status (additional illnesses and conditions commanding higher payments). A previous OIG evaluation found that $6.7 billion in estimated 2017 risk-adjusted payments resulted from chart reviews and not records of services provided in 2016. 

As you can imagine, these findings raised concerns about the completeness of data submitted, the validity of diagnoses on chart reviews, and the quality of care provided. A current OIG evaluation examines the extent to which diagnoses solely generated by health risk assessments (HRAs) were associated with higher risk scores and higher MA payments.

Data from both OIG evaluations will be compared to determine whether certain MAOs and parent organizations had higher or lower amounts of risk-adjusted payments.


Accuracy of Nursing Home Compare Website’s Reported Health, Fire Safety, and Emergency Preparedness Deficiencies

As a helpful resource, CMS’s Nursing Home Compare website provides valuable information, such as quality ratings; the results of recent health, fire safety, and emergency preparedness inspections; staffing levels; quality-of-care measures, and penalties assessed by CMS, for consumers who are researching nursing homes.

The OIG will review the information reported on Nursing Home Compare to determine whether the data is accurate and reliable when comparing nursing homes.


Audit of the Distribution of Supplies From Indian Health Service’s National Supply Service Center in Response to COVID-19

COVID-19 has produced unprecedented challenges for the US hospital system, including Indian Health Service (IHS), Tribal, and Urban Indian Health Program (UIHP) facilities. American Indians and Alaska Natives (AI/AN) are particularly vulnerable to COVID-19 due to the relatively high rates of diabetes, cancer, heart disease, and asthma among these populations.  

Since IHS received funding for medical supplies and equipment through the COVID-19 relief bills allocated to IHS, Tribal, and UIHP facilities, the OIG will determine whether IHS was able to ensure that medical supplies and equipment were effectively distributed to the National Supply Service Center’s customers.


Audit of Foundational Cybersecurity Controls for the U.S. Healthcare COVID-19 Portal and Protect.HHS.gov

There’s been no greater time for informed and timely data than during the COVID-19 pandemic. During the last several months, the general public and healthcare community is continuing to recognize the improvements and innovations that must take place to provide more actionable data for health outcomes, interoperability, and public health transparency.

The urgency and importance of centralized data collection and security is a top priority for health officials and HHS OIG. The Office of Inspector General (OIG) has recognized two critical systems for data management and response to the Coronavirus – Protect.HHS.gov ecosystem and the U.S. Healthcare COVID-19 portal.

HHS OIG will be conducting an audit of foundational cybersecurity controls for the mentioned COVID-19 databases. According to OIG, “Without proper cybersecurity, the integrity and availability of the data are at risk and the impact to public health efforts could be significant if decisionmakers cannot rely on COVID-19 data from states, communities, and hospitals.


Infection Control and Emergency Preparedness at Dialysis Centers During the COVID-19 Pandemic

Many vulnerable populations are being recognized by healthcare professionals and government agencies to build awareness and insights into stopping the spread of COVID-19 and reducing the loss of life in critical situations. Patients and beneficiaries with end-stage renal disease (ESRD), are at higher risk for severe illness from COVID-19.

HHS OIG will be interviewing representatives from the top ESRD service companies to determine whether ESRD facilities implemented additional infection control and emergency preparedness procedures in accordance with CMS and CDC guidance during the COVID-19 pandemic.


Audit of CARES Act Provider Relief Funds—General and Targeted Distributions to Hospitals

HHS OIG will be conducting an audit of the CARES Act Provider Relief Funds (PRF) to determine whether providers that received PRF payments complied with certain federal requirements and the terms and conditions for reporting and expending PRF funds.

During the COVID-19 pandemic, provider organizations have been rewarded relief funds according to 2018 net patient revenue and targeted distributions for certain provider types (e.g., providers in areas particularly impacted by COVID-19, skilled nursing providers, and providers in rural areas).


Find the full list of Recently Added Items on OIG’s site.

Take a look at our recaps of all the archived releases by visiting the ProviderTrust Work Plan page.


Looking for more? Check out the latest compliance resources.

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