The 2021 OIG Work Plan Updates You Need to Know

No surprises here that the OIG keeps chugging away at its Work Plan. In fact, the last couple of months have seen quite a few new items added. So, as part of our ongoing OIG Work Plan Updates series, we’re breaking down some of the most important updates, in case you haven’t had the time to keep up with all of them. Let’s dive right in!

Audits of Laboratory Testing During COVID-19 Pandemic

Take a moment and think about your own health, or the health of your loved ones during the last year. For many of us, laboratory testing probably played a significant part in monitoring our health during the pandemic. Whether lab testing was directly related to COVID or not, the OIG has noticed some data variances in laboratory testing during the time of the pandemic. In response, the OIG recently announced a series of audits.

The OIG’s preliminary analysis has shown that the number of non-COVID-19 tests billed for Medicare Part B beneficiaries during the COVID-19 pandemic has decreased compared with the 6-month period before the pandemic. Many independent laboratories have encountered challenges in providing COVID-19 testing. OIG will conduct a series of audits on Medicare Part B laboratory services conducted during the pandemic that will initially focus on the effect of the pandemic on non-COVID-19 testing. The series of audits will also focus on aberrant billing of COVID-19 testing during the pandemic. Most healthcare providers will probably be interested in these OIG audit results since laboratory testing has been such a huge part of providers’ treatment of patients during the COVID pandemic.

2020 Performance Data for the Senior Medicare Patrol Projects

As opposed to an audit announcement, this work plan item announces a memorandum report that OIG plans to present performance data for the Senior Medicare Patrol (SMP) projects, which receive grants from ACL (Administration for Community Living) to recruit and train retired professionals and other senior citizens to recognize and report instances or patterns of healthcare fraud. The OIG has collected these performance data since 1997. If the SMP work is a new concept for you, I encourage you to visit https://www.smpresource.org/ and learn more.

COVID-19 Vaccination Program

For months during the beginning of the COVID pandemic, we all would have welcomed audits on a vaccination program, as it would mean vaccinations are available! So, in a strange way, the fact that the OIG is announcing their review efforts of a vaccination program is good news in the grand scheme of the pandemic.

Dispensing vaccines effectively and efficiently is a critical step in fighting the COVID-19 pandemic. Generally, it has been States and large metropolitan area public health departments to oversee the vaccine distribution and administration process. These entities are the awardees of the CDC Immunization and Vaccines for Children Cooperative Agreements. And, like any significant medical vaccination program roll out, there were challenges reported by key stakeholders. Awardees have acknowledged challenges early in Phase 1 distribution and dispensing, and note that these challenges will likely span all three phases identified in the CDC's COVID-19 Vaccine Playbook.

The OIG plans to interview all awardees to identify the reported challenges they are facing while distributing and dispensing vaccines. They will also ask awardees about effective strategies to mitigate those challenges, new challenges they anticipate, and how HHS can best support them in distributing and dispensing COVID-19 vaccines. The hope is this review will provide HHS with timely and actionable information to address challenges associated with the COVID-19 vaccination efforts.

Review of Opioid Use in 2020 (Data brief)

For many of us, it might feel as if the entire U.S. Healthcare System has only been focused on the COVID pandemic. But let us not forget the opioid crisis remains a public health emergency in the United States as well. Almost 47,000 people died of opioid-related overdose deaths in the U.S. in 2018. For years, the government has been committed to combating the opioid epidemic which usually first requires identifying patients who are at-risk of overdose or abuse. The COVID-19 pandemic has made this need even more pressing. According to the NIH, this is partly due to the fact that individuals with opioid use disorder might be at particular risk from COVID-19 as it is a respiratory virus that primarily attacks the lungs. Respiratory disease is known to increase mortality risks among people taking opioids.

This proposed OIG data brief will attempt to provide information on opioid utilization among beneficiaries enrolled in Medicare Part D in 2020. It would build on the OIG’s series of reports, including the recent data snapshot Opioid Use in Medicare Part D During the Onset of the COVID-19 Pandemic (OEI-02-20-00400), which reviewed opioid use in Part D during the first 8 months of 2020.

This data brief will provide:

• 2020 data on Part D spending for opioids
• The numbers of beneficiaries who received extreme amounts of opioids through Part D
• Data about those who appeared to be doctor shopping.
• Identification of prescribers who ordered opioids for large numbers of these beneficiaries

Needless to say, opioid use and abuse is still on the OIG’s radar.

If your organization is involved with any of these work plan items, or others recently announced by the OIG, be sure to focus some of your compliance program’s proactive efforts and resources in order to mitigate risk, and ensure compliance.

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