COMPLIANCE PLANS

OIG Work Plan Monthly Review: December 2017

None of the six items the OIG added to its Work Plan this month directly address labs or labs services. However, five of the new items, including the two dealing with opioid abuse, might affect labs indirectly.

1. Prescription Opioid Drug Abuse: Prescription Drug Monitoring Programs

Concern: HHS provides funding to states to prevent opioid abuse and misuse via CDC and the Substance Abuse and Mental Health Services Administration (SAMHSA).

What OIG Will Investigate: The OIG will do a series of audits focusing on states getting HHS funding that have a high or significant increase in the number of overdose deaths to determine: i. what state agencies did with their federal funds for enhancing prescription drug monitoring programs (PDMPs) to improve safe prescribing practices and prevent prescription drug abuse; and ii. whether state agencies complied with federal requirements.

2. Impact of Indian Health Service (HIS) Information Technology & Security Services on Opioid Prescribing Practices

Concern: The IHS’s decentralized management structure and limited cybersecurity resources may be impairing its efforts to implement IT improvements, update its EHR system and combat opioid abuse.

What OIG Will Investigate: The OIG will analyze and compare IT/IS operations and opioid prescribing practices at five IHS hospitals to determine whether: i. IHS’s decentralized management structure has affected its ability to deliver adequate IT/IS services; and ii. Hospitals prescribed and dispensed opioids in accordance with IHS policies and procedures.

3. Paper Check Medicaid Payments Made to Mailbox-Rental Store Addresses

Concern: CMS payments made by paper check to a mailed provider address carry the risk of theft, forgery or alteration. In addition, a recent Government Accountability Office report found that Medicare payments made to a provider who gives its address as a mailbox-rental store, vacant, or invalid practice address increase the potential risk of fraud, waste, or abuse.

What OIG Will Investigate: The OIG will determine whether similar problems exist with Medicaid payment focusing on whether Medicaid payments by paper check sent to providers with mailbox-rental locations were for unallowable services.

4. Status Update on State Medicaid-Provider Enrollment Efforts

Concern: A few years ago, the OIG found that many States hadn’t yet completed fingerprint and background checks and site visits of providers seeking to enroll in Medicaid. But despite assistance from CMS and repeated deadline extensions, the enrollment problem remains unresolved.

What OIG Will Investigate: The OIG will do a Status Update to determine which States have completed the required checks and site visits and try to identify the roadblocks.

5. Review of CMS Medicare Advantage Organization Payment Systems

Concern: CMS is transitioning to a new data systems for making Medicare Part C payments to Medicare Advantage organizations to process risk-adjusted hierarchical condition category (HCC) payment increases.

What OIG Will Investigate: The OIG will review the transition from a data continuity perspective focusing on cases in which CMS made an increased payment to a Medicare Advantage organization for an HCC to determine if CMS systems properly contained a requisite diagnostic code mapping to that particular HCC.

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