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.
May’s agenda includes only 2 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.
- Access to Medication-Assisted Treatment at Health Centers
- Accuracy of Drug Manufacturers’ Quarterly Pricing Data
Access to Medication-Assisted Treatment at Health Centers
The opioid epidemic continues to impact many communities throughout the U.S. and a few concentrated regions of the country. A treatment gap has been identified that is quite alarming – less than 1% of Americans who need treatment for substance abuse disorder are able to receive it. A statistic like this has shaken lawmakers to action by broadening prescribing authorities, enhancing insurance protections, increasing federal funding, and more.
Health centers are crucial local facilities involved in combating opioid abuse because they support and accept patients regardless of their ability to pay, and are able to address both primary and behavioral healthcare services. Health centers administer Medication-Assisted Treatment (MAT) to patients with opioid use disorder with funds delivered by the Health Resources and Services Administration (HRSA).
HHS OIG will be taking a closer look at how many health centers provide Medication-Assisted Treatment as well as many other factors including the number of waivered providers, types of services offered, and the total number of patients receiving MAT.
Accuracy of Drug Manufacturers’ Quarterly Pricing Data
In order to calculate the correct Medicaid rebate amounts and Part D drug reimbursements for beneficiaries, the Centers for Medicare and Medicaid Services (CMS) evaluates the difference between average sales price (ASP) and the average manufacturer price (AMP). If the pricing data is not accurate then Medicare beneficiaries, CMS, and each state can suffer from spending too much for specific prescription drugs.
According to the Social Security Act, HHS OIG is required to compare AMP and ASP data to ensure that potentially excessive spending does not occur. For this new Work Plan item, HHS OIG will be verifying pricing data accuracy from drug manufacturers by national drug codes (NDCs) each quarter. In this way, CMS will be informed of any potential errors in average pricing reporting or potential data errors from each drug manufacturer.
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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.