COMPLIANCE PLANS

OIG Monthly Work Plan Review: October 2018

October saw five new OIG Work Plan items. One has direct implications for labs, while two have potential implications for some labs. These three items are detailed below.

1. CMS Medicare Beneficiary Identifier Card

Issue: The Medicare Access and CHIP Reauthorization Act of 2015 requires CMS to remove Social Security numbers from Medicare cards. As a result, CMS is replacing the existing health insurance claim number with a Medicare Beneficiary Identifier (MBI).

OIG Action: The OIG will conduct a series of reviews to assess controls in place to distribute and implement usage of the MBI. It will determine the number and nature of Medicare cards returned as undeliverable, and the extent to which CMS tracks and follows up on Medicare cards returned as undeliverable. Additionally, OIG will assess CMS’s safeguards in place to protect the MBI. Finally, it will conduct a review of payments to providers to determine whether Medicare cards deemed high risk and cards mailed and returned as undeliverable are being used for inappropriate items and services.

2. Medicaid Capitation Payments Made on Behalf of Incarcerated Individuals

Issue: States contract with Medicaid managed care organizations to provide specific services to enrolled Medicaid beneficiaries, usually in return for a predetermined periodic payment, known as a capitation payment. The Social Security Act and guidance from CMS state that federal financial participation is not available for services provided to inmates of public institutions, except when the inmate is not in a prison setting and becomes an inpatient in a medical institution.

OIG Action: The OIG will determine whether select states made unallowable capitation payments to Medicaid managed care organizations on behalf of individuals who were incarcerated.

3. Data Brief: Early Results from the Opioid State Targeted Response Grants

Issue: The 21st Century Cures Act authorized $1 billion in Opioid State Targeted Response (Opioid STR) grants, to be awarded and overseen by the Substance Abuse and Mental Health Services Administration (SAMHSA). According to SAMHSA, the purpose of these grants is to “address the opioid crisis by increasing access to treatment, reducing unmet treatment need, and reducing opioid overdose related deaths through the provision of prevention, treatment and recovery activities for opioid use disorder.” The majority of funds must be used for opioid treatment services using clinically appropriate evidence-based practices, particularly the use of medication assisted treatment.

OIG Action: The OIG will review early results of the Opioid STR grants, with a focus on states’ use of funds in the first year of the program, including the populations reached and the extent to which grant-funded treatment included medication assisted treatment.

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