3 Key Insights from the OIG’s Work Plan Updates

Let’s delve into the latest Work Plan updates from the U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) as we shed light on crucial developments and initiatives shaping the organization's priorities.

Treatment for Opioid Use Disorder

Treatment with the medication buprenorphine is one of the most common ways to treat individuals with opioid use disorder (OUD), and treatment can prevent unnecessary deaths. Opioid-related overdose deaths are still very high in the United States, as there were an estimated 82,310 deaths in 2021. For beneficiaries enrolled in Medicare Part D, buprenorphine can be used effectively to help patients who struggle with OUD. Some studies show that when treatment medications such as buprenorphine are discontinued, the likelihood of overdose deaths increases.  The longer a patient can be retained in treatment the better their outcomes are, and rates of emergency room visits also go down.

The OIG wants to look at the extent to which people enrolled in Medicare Part D maintain buprenorphine treatment for at least six months. Their work will also look at the extent to which these enrollees – including the setting in which they start their treatment and the services they receive – differ from enrollees who do not maintain treatment.

This work plan item adds to list of opioid-related OIG Work Plan items over recent years.

Transitional Living Program

In fiscal year 2022, the HHS’s Administration for Children and Families (ACF) provided more than $53 million in funding awards to grant recipients for administering the Transitional Living Program (TLP). TLP is designed to support the delivery of certain services for homeless young people aged 16-21.

Some of these services include:

1. 1. Providing shelter (i.e., group homes, maternity group homes, host family homes, and supervised apartments),
   2. A service coordination plan that refers youths experiencing homelessness to social services, law enforcement, educational services, vocational training, child welfare, legal services, affordable childcare, or child education programs, and
   3. A transitional living plan that provides basic life skills, money management, job attainment skills, counseling, mental and physical health care, other youth development services, and after-care resources to support the transition from supervised participation to independent living.

With the addition of this Work Plan item, the OIG stated they want to determine whether some of the 175 TLP grant recipients followed Federal requirements when providing services to youths experiencing homelessness.

Chasing COVID Monies

Compliance professionals who have been working in the field for a while have likely noticed that enforcement agencies chase dollars associated with government funding initiatives. And there was no other funding initiative larger than the federal dollars expended during the COVID-19 public health emergency. Now is the time the OIG and other agencies are checking if recipients of those funds expended them appropriately and did not “double dip,” so to speak.

One of the funding sources was the HHS Health Resources and Services Administration (HRSA). They awarded supplemental grant funding of approximately $8.1 billion to 1,387 health centers nationwide during 2020-2022. These particular funds were intended to support the health centers' activities related to the detection, prevention, diagnosis, and treatment of COVID-19. This also included expansion of COVID-19 testing and administering COVID-19 vaccines.

During the same time, there was separate HRSA funding via the Uninsured Program (UIP).  This program reimbursed providers more than $24.5 billion for conducting COVID-19 diagnostic testing and providing testing-related items and services to uninsured individuals. However, the terms and conditions of UIP stated that recipients should consider payments from the UIP to be payment in full for COVID-19 testing and/or testing-related items, vaccine administration, care, or treatment.  In other words, health centers should have accepted any UIP payments as payment in full and should not have charged any of the same costs to their COVID-19 supplemental grant funding, including the difference between the amount claimed to the UIP and the amount they were reimbursed by the UIP.

The OIG stated their past work identified some health centers charged costs for processing COVID-19 tests to their COVID-19 supplemental grant funding and also submitted claims and received reimbursement for the same services from the UIP.

With that in mind, this current Work Plan item is intended to determine if health centers that submitted claims for COVID-19 testing and received reimbursement from the UIP also received reimbursement from grant funding for the same costs.

As always, if any of these new work plan items apply to your organization, it might be wise to proactively review these activities before the OIG does.

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