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.
March’s agenda includes 16 new items from HHS Office of Inspector General (OIG). Let’s walk through some of the latest releases so you can address each item within your compliance program, if applicable.
- Medicaid Fraud Control Units Fiscal Year 2018 Annual Report
- Opioid Use in Medicare Part D in States in the Appalachian Region
- Post-Hospital Skilled Nursing Facility Care Provided to Dually Eligible Beneficiaries
- Review of HHS’s Compliance with the Federal Information Security Modernization Act of 2014 (FISMA)
- Fiscal Year 2018 Performance Data for the Senior Medicare Patrol Projects
- Review of Medicare Administrative Contractor Information Security Program Evaluations for FY 2018 (MMA 912)
Medicaid Fraud Control Units Fiscal Year 2018 Annual Report
Medicaid Fraud Control Units (MFCU) are responsible for state enforcement of government healthcare fraud and report to the Office of Inspector General (OIG). On June 1, 2012, the Federal Register published an important mandate to measure the success of each state MFCU.
According to Performance Standard 8(f), all state Medicaid Fraud Control Units are required to transmit to the OIG for HHS, “for purposes of program exclusions under section 1128 of the Social Security Act, all pertinent information on MFCU convictions within 30 days of sentencing, including charging documents, plea agreements, and sentencing orders.” Id. p. 32648.
The upcoming annual report will be used to analyze reported statistics in 2018 from all MFCUs. The OIG will be assessing MFCU’s compliance with policy and regulations, as well as their adherence to performance standards.
Read the full update from OIG.
Opioid Use in Medicare Part D in States in the Appalachian Region
The impact of opioid abuse has been felt by so many communities throughout the United States. Appalachia remains a concentrated area for such activity and leads the country in the number of overdose deaths each year.
To better assess this epidemic, the Office of Inspector General (OIG) will be evaluating five states (AL, KY, OH, TN, WV) for Medicare Part D prescription opioid use. The data brief will include both the amount of individuals who have received an opioid prescription, as well as how many beneficiaries may be at serious risk of opioid overdose or misuse.
Find out more information on the OIG website.
Post-Hospital Skilled Nursing Facility Care Provided to Dually Eligible Beneficiaries
Recently, OIG has placed a large emphasis on Skilled Nursing Facilities and assessing how vulnerable these environments are for fraud, waste, and abuse. Specifically, OIG has been looking into instances when beneficiaries are eligible for both Medicare and Medicaid services and whether or not the proper procedures have taken place for the integrity of federal dollars.
Many times, nursing facilities are incentivized to bill Medicare instead of Medicaid because of the significant difference in the payment amount, in which case, these organizations choose to increase the level of care to beneficiaries to, “skilled”. The OIG will be determining if improper payments were made based on claims data.
To read more about this report visit the OIG’s site.
Review of HHS’s Compliance with the Federal Information Security Modernization Act of 2014 (FISMA)
According to the Federal Information Security Modernization Act of 2014, agencies and their contractors are required to maintain programs that have adequate controls in place for security. This rule applies to information collected, processed, transmitted, stored, or disseminated in major applications and support systems.
The Office of Inspector General (OIG) will be reviewing the HHS operating division’s compliance with FISMA. To read the full update, visit the HHS OIG website.
Fiscal Year 2018 Performance Data for the Senior Medicare Patrol Projects
HHS OIG has collected performance data from this program since 1997 and will be organizing the information into a report. Take a look at this update here.
Review of Medicare Administrative Contractor Information Security Program Evaluations for FY 2018 (MMA 912)
Medicare Administrative Contractors (MACs) are required to have independent evaluations of their security programs and report the results to Congress according to the Medicare, Prescription Drug, Improvement, and Modernization Act of 2003.
HHS OIG will be summarizing results from these evaluations and reporting to Congress. Take a look at some of the details here.
Other updates to the March 2019 OIG Work Plan include the following:
- Potential Duplication of NIH Research Grant Funding
- Medicare Part B Drug Payments: Impact of Price Substitutions Based on 2017 Average Sales Prices
- Medicare Market Shares of Mail Order Diabetes Test Strips
- HHS Agencies’ Annual Accounting of Drug-Control Funds – Mandatory Review
- Review of HHS Government Purchase, Travel, and Integrated Charge Card Programs
- HHS Compliance with the Improper Payment Elimination and Recovery Act
- OIG DATA Act Readiness Review (2016) and Data Completeness and Accuracy (2017, 2019, 2021). (Performing a scaled down version on an interim basis for FY 2018.)
- Audit of FY 2019 HHS Consolidated Financial Statements
- Audit of FY 2019 CMS Financial Statements
- Superfund Financial Activities at the National Institute of Environmental Health Sciences
Do you have any recent experience or information concerning OIG’s Work Plan updates for March?
Maybe there’s a question you are urgent to ask for more insight. Let us know in the comments below!
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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.