3 New OIG Work Plan Updates in April 2023

The OIG added three items to their Work Plan in April 2023 – let's take a look at the areas on their radar.

Audits of COVID Funds

The COVID-19 Public Health Emergency saw money pouring out of Washington, D.C. Two different acts passed by Congress and signed into law made $2.7 billion available for a program run by the Centers for Disease Control and Prevention (CDC) called “The Public Health Crisis Response Cooperative Agreement” program. The idea was for the CDC to award state, local, and tribal governments funding and resources to prevent, prepare for, and respond to the COVID-19 pandemic.

The money was given out rather quickly and OIG believes some recipients of those program funds might not have had adequate procedures in place to make sure the funds were used in the intended manner.

Because of this, the OIG plans to perform a series of audits on select cooperative agreements with recipients. For each audit, their objective will be to determine whether recipients used the program funds according to Federal requirements and applicable award terms and conditions.

Remote Patient Monitoring Services

In the Western District of New York, a company that provided remote cardiac monitoring services agreed to pay over $600,000 to settle allegations of false claims violations. In another case, a company agreed to pay over $44 million to settle similar allegations, which also involved the remote monitoring of clinical services.

Many categorize remote patient monitoring as a form of telehealth services. The ability to monitor certain aspects of a patient's health from their own home has become an increasingly popular telehealth option. Remote patient monitoring lets providers manage acute and chronic conditions, and it cuts down on patients' travel costs and infection risk.

The Centers for Medicare and Medicaid Services (CMS) define remote patient monitoring as the “use of digital technologies to collect health data from patients in one location and electronically transmit that information securely to providers in a different location (data can include vital signs, weight, blood pressure, blood sugar, pacemaker information, etc.).” Many states’ Medicaid programs also cover remote patient monitoring in some form.

These services have the potential to significantly increase, which would result in higher spend from government health plans like Medicare and Medicaid. Whenever that is the case, providers need to be aware of increased scrutiny and auditing relating to these services.

OIG states there is currently limited research on the use of remote patient monitoring services, such as the types of patients and providers who use these services, and the health conditions that are monitored through these services, among other details.

With that in mind, the OIG plans to conduct reviews related to remote patient monitoring services. This particular review will be based on Medicare fee-for-service claims and Medicare Advantage encounter data for remote patient monitoring services. It will look at the extent to which the use of remote patient monitoring services has changed, the nature of remote patient monitoring services being used by Medicare enrollees, and the characteristics of enrollees using remote patient monitoring services.

And, of course, it wouldn’t be a good OIG review if there also wasn’t any focus on the extent to which provider billing for remote patient monitoring services may indicate fraud, waste, or abuse.

Adverse Events Toolkit

Last year, the OIG issued an interesting report that concluded that 25% of Medicare patients experienced patient harm during their hospital stays. These events led to longer hospital stays, permanent harm, life-saving intervention, or death. Beyond these more significant adverse events, the report also concluded that 13% of patients experienced temporary harm events, which required intervention but did not cause lasting harm, prolong hospital stays, or require life-sustaining measures. Temporary harm events were sometimes serious and could have caused further harm if providers had not promptly treated patients.

This same report categorized some of the most common types of harm events as those related to:

• • Medication (43 %)
  • Patient care (23%), which included pressure injuries
  • Procedures and surgeries (22%), such as intraoperative hypotension
  • Infections (11%), such as hospital-acquired respiratory infections

With this backdrop, the OIG is promising their release of a “toolkit” with clinical guidance for identifying harm. The goal, of course, is to implement ways to reduce adverse events in the inpatient hospital setting. OIG states the toolkit will include a compendium of guidance they will develop or adopt for assessing the care associated with 29 specific conditions and injuries. For each condition, they will discuss how they determined whether the condition was the result of harm and whether it could have been prevented. They will also include information about the hospital trigger tool reviewers used to screen for adverse events, and suggestions for finding and recording key information.

Conclusion:

Compliance professionals should be proactive instead of reactive and take a look at these areas if they are pertinent to your organization’s provided services.

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