Each month, we are pleased to share the most recent additions to the 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 points from this month.
A few topics that stood out to us for May’s OIG Work Plan are the following:
- 2017 Hurricane Emergency Preparedness and Response Efforts
- The Impact of Authorized Generics on Medicaid Drug Rebates
- States’ Procurement of Private Contracting Services for the Medicaid Management Information System
Find the full list of Recently Added Items on OIG’s site.
This month’s agenda includes 7 new items from OIG. Let’s walk through some of these updates so you can address each item within your compliance program, if applicable.
2017 Hurricane Emergency Preparedness and Response Efforts
Hurricane season last year was one that we will most certainly never forget. Many people were affected by these traumatic events that involved 3 major hurricanes in the United States: Harvey, Irma, Maria.
After these disasters, $5.97 billion in funds for preparation and response were allocated to HHS. The OIG will be assessing and auditing HHS’s primary risks for this hurricane preparation and response and identify internal controls for such matters when large funding is disbursed.
Read the full update from OIG here.
The Impact of Authorized Generics on Medicaid Drug Rebates
According to the Affordable Care Act, primary drug manufacturers were directed by the Centers for Medicare and Medicaid Services to include the sale of authorized generic drugs to secondary manufacturers in some instances (42 CFR 447.506(b)) in determining the average manufacturer price (AMP). It’s been uncovered by OIG that inclusion of these sales in the average calculation may have greatly reduced the AMP and Medicaid rebates.
To find out more about how OIG is addressing this scenario with the Medicaid Drug Rebate Program, visit here.
States’ Procurement of Private Contracting Services for the Medicaid Management Information System
Many times states will use private resources to design, develop, and operate their Medicaid Management Information System (MMIS). During the procurement process, states are required to follow the same policies and procedures used for procurements paid with non-Federal funds.
In addition, CMS must approve each state’s acceptance of enhanced Federal matched funds for MMIS admin costs when it comes to private companies or contractors hired.
Read more on this review here.
Other updates to the May 2018 OIG Work Plan include the following:
- Examining Healthcare Coalitions’ Partnerships With Non-Hospital-Based Facilities in Community Preparedness Efforts
- Medicare Part B Outpatient Cardiac and Pulmonary Rehabilitation Services
- Noninvasive Home Ventilators – Compliance With Medicare Requirements
- Recommendation Follow up: 2014 OIG Report: Vulnerabilities in the HHS Small Business Innovation Research Program
Do you have any recent experience or background information concerning OIG’s Work Plan updates for May? 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.