OIG Work Plan Update: New Items Added

There were three Covid-19 related OIG Work Plan updates released last week that I discussed in my Thursday Thoughts. However, on June 15, 2020, the OIG released another 12 updates, all of which are issued by the Office of Evaluation and Inspections, as well as the Office of Audit Services.

It is critical for providers, practices, and organizations alike to review these monthly updates to better assess their own deficiencies, take corrective actions, tighten up compliance policies, and ensure any future scrutiny by a government or commercial payor can be met with confidence and successful outcomes.

1. Medicaid—Telehealth Expansion During COVID-19 Emergency - As a result of the coronavirus disease 2019 (COVID-19) pandemic, State Medicaid programs have expanded options for telehealth services. OIG objective is to determine whether State agencies and providers complied with Federal and State requirements for telehealth services under the national emergency declaration, and whether the States gave providers adequate guidance on telehealth requirements. (expected issue date FY 2021)
2. Audit of Foster Care Services During Coronavirus Disease 2019 (COVID-19) - The OIG intends to survey all States and identify the States that adopted any new licensing regulations or policies and procedures as a result of the existing flexibilities in the Statute and the waivers provided by ACF. Based on the information gathered, they plan to identify three States and conduct separate audits to ensure foster care providers are safeguarding the health and safety of children during the COVID-19 pandemic and identify any vulnerabilities or gaps in policies or procedures that could place these children at risk. As part of these audits, they would ensure that criminal record checks for foster parents conducted via name-based checks were ultimately conducted through fingerprints whenever determined safe to do so. (expected issue date FY 2021)
3. Medicare Payments for Clinical Diagnostic Laboratory Tests in 2019: Year 2 of the New Fee Schedule Rates - The OIG will publicly release an analysis of the top 25 laboratory tests by expenditures for 2019 and analyze the payments made under the new payment system in 2019, the second year of payments made under the new system for setting payment rates. (expected issue date FY 2021)
4. Audit of Cost Allocation Services' Negotiation and Approval of Indirect Cost Rates for Nonprofit Organizations - Previous OIG audits of nonprofit organizations have raised concerns about the indirect cost rate negotiations and subsequent agreements. Their objective will be to assess CAS's indirect rate setting process and determine its compliance with Federal regulations when negotiating and approving indirect cost rates for nonprofit organizations. (expected issue date FY 2021)
5. Advanced Care Planning Services: Compliance With Medicare Requirements - Previous reviews have shown improper payments due to a lack of clinical documentation to support face-to-face services, clinical documentation of the time spent discussing ACP, or both. The OIG plans to perform a nationwide audit to determine whether Medicare providers for ACP services complied with Federal regulations. (expected issue date FY 2021)
6. Opioid Use in Medicare Part D in 2020 - The OIG will provide 2020 data on Part D spending for opioids and the number of beneficiaries who received extreme amounts of opioids through Part D and those who appeared to be doctor-shopping. It will also identify prescribers who ordered opioids for large numbers of these beneficiaries. (expected issue date FY 2021)
7. Audit of the Department of Health and Human Services' Progress Toward Compliance With the Geospatial Data Act of 2018 - GDA requires the inspector general of each executive department (or the senior ethics official of each executive department without an inspector general) to submit to Congress not less than once every 2 years an audit of the collection, production, acquisition, maintenance, distribution, use, and preservation of geospatial data by Federal agencies. The purpose of this audit is to determine progress toward compliance with GDA. (expected issue date FY 2021)
8. Data Snapshot: Medication-Assisted Treatment From Providers Waivered at the Highest Patient-Limit Level - This snapshot will report how many patients are receiving medication-assisted treatment (MAT) services from 275-limit waivered providers. The OIG will also report how many of these providers are located in high-need counties and how many are treating at or near their capacity limit. They will also determine how many 275-limit waivered providers have reported their patient data to Substance Abuse and Mental Health Services Administration (SAMHSA), as required. (expected issue date FY 2021)
9. Utilization of Medication-Assisted Treatment in Medicare - This study will assess the extent to which Medicare beneficiaries with opioid use disorder are receiving medication-assisted treatment (MAT) drugs through Medicare and the extent to which they are receiving counseling or behavioral therapies. It will also determine whether Medicare beneficiaries with opioid use disorder who are not receiving MAT drugs have certain characteristics in common. (expected issue date FY 2021)
10. Results of UPICs' Benefit Integrity Activities - This study will continue OIG's work examining the results from benefit integrity contractors' identification and investigation of fraud, waste, and abuse. It also will identify any barriers and challenges UPICs have experienced while conducting unified benefit integrity activities across Medicare and Medicaid. (expected issue date FY 2022)
11. Audit of Grantee's Expenditures Under the Additional Supplemental Appropriations for Disaster Relief Requirement Act, 2018 - The OIG will determine whether Further Additional Supplemental Appropriations for Disaster Relief Requirement Act, 2018, recipients claimed allowable costs in accordance with Federal requirements (for Hurricanes Harvey, Irma, and Maria). (expected issue date FY 2021)
12. Penetration Tests of State Medicaid Management Information Systems and Eligibility & Enrollment Systems - OIG will perform a series of penetration tests in select State Medicaid Management Information System (MMIS) or Medicaid Eligibility and Enrollment (E&E) environments to identify cybersecurity vulnerabilities on high-risk information systems and networks. (expected issue date FY 2021)