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 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 October agenda includes 12 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.
Ineligible Providers in Medicare Part C and Part D
CMS contracts with Medicare Advantage plans and private prescription drug plans to offer Part C and Part D benefits to qualified recipients. Federal law prohibits 1) Medicare payments for services and prescriptions given by Federally-excluded providers and 2) Medicare payments to ineligible providers whose billing privileges have been deactivated, denied, or revoked. OIG will conduct an audit of 2018-2019 Medicare Part C and D managed care data to identify two items. The first is to discover ineligible providers who rendered services through Part C and D sponsors. The second is to determine whether these sponsors complied with Federal requirements by preventing ineligible providers from rendering services to Medicare beneficiaries.
OIG Oversight of State Medicaid Fraud Control Units
The 50 State Medicaid Fraud Control Units (MFCUs), located in 49 states and the District of Columbia, investigate and prosecute Medicaid provider fraud and patient abuse complaints in Medicaid-funded facilities. OIG not only provides on-site inspections, technical assistance, and training for the MFCUs, offers a Federal grant award that provides 75 percent of its funding. The OIG will continue to perform on-site reviews of a sample of MFCUs.
Mandatory Review of HHS Agencies’ Accounting of National Drug Control Program Funds
Under 21 U.S.C. § 1704, The Office of National Drug Control Policy circular, Accounting of Drug Control Funding, and Performance Summary require agencies to submit physical documentation of expenditures made during the previous fiscal year. The policy also requires that an agency offer its annual accounting and authentication to verify its declarations further. If an agency’s prior year drug-related commitments were less than $50 million, the agency will not be subjected to these terms. OIG will review how H.H.S. agencies complied with this circular starting with F.Y. 2020, continuing every three years.
Joint Work With State Agencies
OIG is partnering with State auditors, State comptrollers general, and State inspectors general to strengthen program integrity, efficiently use audit resources, and provide more extensive oversight of the Medicaid program. These partnerships will address improper payments in fee-for-service programs such as home health, hospice, and durable medical equipment, and in managed care.
OIG will partner with States to (1) address known vulnerabilities in both Medicare and Medicaid to curb such vulnerabilities, and (2) identify new areas that put the Medicaid program at risk.
Audit of Health Resources and Services Administration’s COVID-19 Uninsured Program
The Families First Coronavirus Response Act (FFCRA) and the Paycheck Protection Program and Health Care Enhancement Act (PPP) jointly allocated $2 billion to reimburse providers for COVID-19-related expenditures used on uninsured patients. A portion of the $175 billion disbursed to the Provider Relief Fund by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and PPP will be used for treating uninsured individuals with a confirmed COVID-19 diagnosis. Healthcare providers can submit their reimbursement claims for COVID-19 tests and treatment through a single electronic claims processing system called the COVID-19 Uninsured Program Portal.
OIG will determine whether the COVID-19 diagnostic testing and treatment service reimbursements complied with Federal requirements.