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 its 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 January agenda includes 3 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.
- Early Discharges From Inpatient Rehabilitation Facilities to Home Health Services
- Audit of Office of Refugee Resettlement’s Placement and Transfer of Children in the Unaccompanied Alien Children Program
- Medicaid-Audit of Medicaid Eligibility Determinations for States in Cycle 1 of CMS’s PERM Review
Early Discharges From Inpatient Rehabilitation Facilities to Home Health Services
The Centers for Medicare and Medicaid Services (CMS) established an early transfer payment policy for inpatient rehabilitation facilities for transfers to another IRF, an inpatient hospital, a nursing home that accepts payments under Medicare or Medicaid, or a long-term-care facility.
Because the IRF prospective pay system had recently been developed, the Centers for Medicare and Medicaid Services (CMS) excluded IRF discharges to home health services due to claims data not being able to be analyzed.
HHS OIG will be determining how an IRF transfer payment policy for early discharges to home health services would financially affect Medicare Part A and IRFs.
Audit of Office of Refugee Resettlement’s Placement and Transfer of Children in the Unaccompanied Alien Children Program
HHS OIG will be determining whether the Office of Refugee Resettlement (ORR) followed its policies, procedures, and guidance both when making initial placements in care provider facilities funded by ORR and when transferring children between those facilities.
They will also be reviewing the following as related to transfers:
- How frequently children are transferred between care provider facilities
- Reasons for transfers and denials of transfers
- Challenges that care provider facilities face when children are identified as requiring a transfer
Medicaid-Audit of Medicaid Eligibility Determinations for States in Cycle 1 of CMS’s PERM Review
The Centers for Medicare and Medicaid Services (CMS) developed the Payment Error Rate Measurement (PERM) program to measure improper payments in the Medicaid program. In accordance with the Improper Payments Information Act of 2002, Federal agency administrators are required to annually review programs they administer to identify if they are susceptible to significant improper payments, and also estimate the amount of improper payments.
Medicaid has been identified as a program at risk for significant improper payments over the years. In 2017, CMS made changes to PERM and Medicaid Eligibility Quality Control (MEQC) programs to reduce state burden, improve program integrity, and promote state accountability through policy and operational improvements. HHS OIG will be evaluating the adequacy of the PERM program by determining whether the federal contractor conducted eligibility reviews in accordance with federal PERM requirements.
Check out our latest resources!
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.