COMPLIANCE PLANS

OIG Work Plan Monthly Review: March 2018

One of the seven new items on the OIG’s Work Plan this month, one deals with child support. Among the six items focusing directly on health care, none directly address clinical laboratories or diagnostic testing. However, a few labs may be indirectly affected by some of the new items depending on the services they provide, school program testing, and programs in which they participate, e.g., Indian Health Services.

1. Medicare Part D Opioid Use Data Brief

Issue: Of the 52,000 drug overdose deaths in the US in 2015, over 33,000 involved opioids. In 2016, the problem got worse with over 175 drug overdose deaths per day.

OIG Action: The OIG plans to create a data brief providing updated data on Part D spending for opioids, the number of beneficiaries receiving extreme amounts of opioids through Part D and the number of beneficiaries who appear to be “doctor shopping.”

2. ACL Oversight of Independent Living Programs

Issue: As part of the Administration for Community Living (ACL) sponsorship of nationwide programs supporting independent and community living for people with disabilities. Among its other oversight responsibilities, the ACL conduct onsite compliance reviews of at least:

  • 15% of Centers for Independent Living that receive funding under Title VII of the Rehabilitation Act of 1973; and
  • One-third of designated State units that receive funding under the Act.

OIG Action: The OIG will review the ACL’s plan for compliance with the onsite review requirements and ACL oversight activities for monitoring independent living programs.

3. Compliance with Grantee Cost Principles by Organizations with Multiple HHS Discretionary Funding Sources

Issue: HHS grantees are required to maintain financial management systems that contain written procedures for determining the reasonableness, allocability and allowability of costs in accordance with applicable federal cost principles and the terms and conditions of the award, as well as accounting records supported by source documentation.

OIG Action: The OIG plans to review select grantees receiving HHS grant funding from multiple sources to determine whether they are allocating and claiming costs in accordance with federal requirements and review current HHS procedures for oversight and coordination between the participating grant programs.

4. Adverse Events in IHS Hospitals

Issue: The Indian Health Service operates 26 hospitals offering free inpatient care to eligible American Indians and Alaska Natives, many of which are located in remote areas and have low average daily patient censuses.

OIG Action: The OIG will identify adverse and temporary harm events at IHS hospitals in FY 2017 and estimate the incidence and preventability of these events by reviewing medical records associated with a sample of inpatient stays. It will also assess the extent to which IHS hospitals recorded these events in their incident reporting systems.

5. Financial & Administrative Review by IHS Area Offices

Issue: Congress has expressed concern about IHS’s administrative and financial management of program funds to provides health services to approximately 2.2 million American Indians and Alaska Natives in 567 federally recognized Tribes located in 35 states. These services are funded through annual appropriations distributed among IHS headquarter offices and 12 regional offices called Area Offices. These services are provided through IHS and Tribal facilities that operate (1) IHS direct health care service programs, (2) tribally operated health care service programs authorized under Titles I and V of the Indian Self-Determination and Education Assistance Act (P.L. No. 93-638), and (3) Urban Indian Health Program services and resource centers.

OIG Action: The OIG will examine how an IHS Area Office monitors and allocates appropriations received from IHS headquarter offices within its geographic area and examine an Area Office with respect to accounting for IHS annual appropriations and allocating IHS appropriations to service units within the Area Office’s geographic area.

6. Medicaid School-Based Costs Claimed Based on Contingency Fee Contractor Coding

Issue: During a previous review, the OIG found that one consultant of a state Medicaid agency paid a contingency based on the percentage of federal funds reimbursed to the state developed unsupported time studies that it used to develop payment rates for school-based health services. Based on those rates, the state claimed unallowable federal funds. Consultants in many other states also developed time studies using a similar methodology.

OIG Action: The OIG will do a multiple state review with a roll-up report to CMS to determine whether consultants developed school-based Medicaid rates based on unsupported time studies and unallowable costs in those states.

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