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 July agenda includes 16 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. CMS and States Implement Policy Modifications To Ensure That Medicaid Beneficiaries Continue To Receive Prescriptions
  2. Use of Medicare Telehealth Services During the COVID-19 Pandemic
  3. Basic Health Program Eligibility Determinations
  4. Medicaid: Expedited Provider Enrollment During COVID-19 Emergency
  5. Geographic Distribution of Provider Relief Funds to Communities Disproportionately Impacted by Adverse COVID-19 Outcomes
  6. CDC’s Collection and Use of Data on Disparities in COVID-19 Cases and Outcomes
  7. Audit of HHS’s Awarding of Ventilator Production Contracts Under the Defense Production Act in Response to COVID-19
  8. Audit of Indian Health Service’s Coverage of COVID-19 Testing

CMS and States Implement Policy Modifications To Ensure That Medicaid Beneficiaries Continue To Receive Prescriptions

In times of emergency, CMS may temporarily waive or modify certain Medicaid requirements to ensure that sufficient healthcare items and services are available to meet the needs of beneficiaries. COVID-19 has highlighted the requirement for each state Medicaid agency to meet the needs of the public, and access to prescriptions is so important with many in-person visits being suspended at this time.

HHS will be conducting an audit to provide insights from state officials on action taken by states and DC to ensure Medicaid beneficiaries continue to receive prescriptions during the COVID-19 pandemic.


Use of Medicare Telehealth Services During the COVID-19 Pandemic

The Centers for Medicare and Medicaid Services (CMS) has made quite a few changes and exceptions for telehealth and virtual care services during COVID-19. These updates have made it much easier for Medicare beneficiaries to receive care without in-person visits or having to travel to a healthcare facility. Once the federal government declared the national public health emergency, many state medical boards made exceptions for license portability and credential renewal dates.

HHS OIG will be conducting two reviews based on Medicare Parts B and C telehealth data during the pandemic. The department hopes to find out more information about the extent to which beneficiaries are utilizing telehealth services, the use of these services versus in-person care, and the types of providers and beneficiaries who are using virtual care most often.


Basic Health Program Eligibility Determinations

Section 1331 of the Affordable Care Act (ACA) gives states the option to create a Basic Health Program (BHP) that provides health benefits coverage for low-income residents, citizens or lawfully present non-citizens, who would otherwise be eligible to purchase coverage through the Health Insurance Marketplace. BHPs are funded primarily by federal funds and must include 10 essential health benefits specified by the ACA.

The study from HHS OIG will determine whether states made Basic Health Program (BHP) payments on behalf of beneficiaries who did not meet Federal and State eligibility requirements.


Medicaid: Expedited Provider Enrollment During COVID-19 Emergency

During national emergencies, state Medicaid agencies may expedite the provider enrollment process under the SSA §1135 authority to waive certain requirements. According to HHS OIG, “Rapid loosening of established provider screening and background check requirements may limit a state’s ability to identify providers who are not eligible to participate in Medicaid.”

HHS will be evaluating how states established tracking controls for these providers as well as giving providers adequate guidance on waived enrollment requirements.

Exclusion and sanction screening is critical, even during a pandemic and national health emergency.

Learn more about how to monitor providers and entities.

Geographic Distribution of Provider Relief Funds to Communities Disproportionately Impacted by Adverse COVID-19 Outcomes

Data continues to come in regarding rates of infection and outcomes for the COVID-19 pandemic. Numerous reports document racial, ethnic, and socioeconomic disparities in rates of adverse outcomes from COVID-19, including death.

HHS OIG will review the locations of hospitals that received Provider Relief Funds, with particular attention to hospitals located in minority and economically disadvantaged communities that were disproportionately impacted by adverse COVID-19 outcomes


CDC’s Collection and Use of Data on Disparities in COVID-19 Cases and Outcomes

The Coronavirus pandemic is highlighting many of the inequities of healthcare and how disproportionately some communities are being affected by the virus. HHS OIG will be conducting a study that will examine CDC collection and use of data to assess racial, ethnic, and socioeconomic disparities in COVID-19 cases and outcomes.

The study will also be evaluating how the CDC is using this data to address the pandemic, and also lessons learned about how to best protect communities of color and economically disadvantaged communities in future public health emergencies.

Join our September Webinar

September 30, 2020 at 12 PM CST.

Racial Inequities and Minority Representation in Healthcare


Audit of HHS’s Awarding of Ventilator Production Contracts Under the Defense Production Act in Response to COVID-19

Supply chain management and procurement services have truly been tested during the national public health emergency. In fact, many organizations are starting to become more aware of the fraud, waste, and abuse that can take place in our federal healthcare programs from bad actors looking to take advantage during a chaotic time. Once the pandemic starts to become more controlled, we expect to see compliance standards change in regard to PPE and healthcare supply chains.

The President used his authority under the Defense Production Act of 1950 to direct the HHS to facilitate the supply of materials for the production of ventilators to address the pandemic. Many new government contracts were put in place to gather resources for the Strategic National Stockpile.

HHS OIG will perform an audit on the top five highest dollar value contracts awarded by ASPR for supplying ventilators. OIG aims to determine whether ASPR’s awarding and monitoring of these contracts complied with federal requirements and HHS policies and procedures.


Audit of Indian Health Service’s Coverage of COVID-19 Testing

The Indian Health Service (IHS) has received multiple funds for COVID-19 testing and testing-related services. OIG will audit IHS’s allocation and utilization of COVID-19 funding to urban Indian organizations.

The audit will be focusing on two main questions: 

  1. Did IHS allocate the COVID-19 funds to ensure that testing supplies were available to meet community needs?
  2. Were COVID-19 funds used by IHS and grantees for testing, including other testing-related services, in accordance with federal requirements?

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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