CJ Wolf
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compliance, skilled nursing facilities, oig work plan, Medicare Part D, OIG Work Plan Updates, patient care, OIG Work Plan 2023
Let’s take a look at the areas on the U.S. Department of Health and Human Services Office of Inspector General’s (OIG) radar in May 2023.
Opioid Use in Medicare Part D
The fight in the opioid epidemic continues and compliance enforcement is an essential part of that effort. Each year, the OIG produces a data brief on opioid use in Medicare Part D. These briefs provide information on opioid utilization among those who are enrolled in Medicare Part D. This announced data brief will summarize information pertinent to 2022.
One of the data points includes the number of enrollees who received extreme amounts of opioids through Part D and those who appeared to be doctor shopping. It also identifies prescribers who ordered opioids for large numbers of these enrollees.
Information shared in past data briefs indicates what we will likely see in this 2022 report. In the 2021 report, OIG stated that about 50,400 Medicare Part D beneficiaries experienced an opioid overdose in 2021. Almost a quarter of Part D beneficiaries received opioids during the year.
More than 1 million Medicare beneficiaries had a diagnosis of opioid use disorder in 2021, yet fewer than 1 in 5 received medication to treat their opioid use disorder. The number of Part D beneficiaries receiving prescriptions for the opioid overdose reversal drug Naloxone through Part D grew.
The OIG expects to release the 2022 date brief sometime in 2023.
Hospital Identification of Patient Harm Events
In May of 2022, OIG issued a report titled “Adverse Events in Hospitals: A Quarter of Medicare Patients Experienced Harm in October 2018.” This was significant news. In that report, the OIG concluded that “…hospital care associated with these events cost Medicare and patients an estimated $324 million in reimbursement, coinsurance, and deductible payments. Nearly half of these events were preventable.”
In this newly announced Work Plan item, OIG intends to determine the extent to which hospitals identify patient harm events and report those events to external entities. Hospitals that participate in Medicare collect information about patient harm events to meet Medicare requirements to measure, analyze, and track adverse patient harm events. These organizations have implemented incident reporting systems enabling providers and hospital staff to report information about patient safety incidents when they occur.
In addition, hospitals use other surveillance systems to capture events within specific hospital departments, such as the hospital pharmacy, or to capture specific types of adverse events, such as infections. Then, hospitals analyze this information to identify trends and root causes of safety issues to improve care and prevent recurrences of harm events.
The OIG is planning to use the harm events identified through medical review as the basis for this new Work Plan review.
Nursing Home Facility-Initiated Discharges
You may have seen recent news stories about elderly residents being “evicted” from nursing homes. (See https://www.washingtonpost.com/business/2023/04/06/seniors-assisted-living-medicaid-eviction/
These stories have not gone unnoticed by HHS OIG. And in May 2023, they added a new Work Plan item to learn more about it.
Specifically, they want to study and issue a data brief on those transfers or discharges that are initiated by the nursing home facility. The concern is some of these discharges can be an unsafe and traumatic experience for the resident and the resident's family.
In 1987, Congress passed the Nursing Home Reform Act to protect residents against inappropriate facility-initiated transfers and discharges. But, according to the OIG, data from the National Ombudsman Reporting System show that from 2011 through 2016 the Long-Term Care Ombudsman Program cited complaints related to "discharge/eviction" more frequently than any other concern.
The OIG has ongoing work examining the extent to which nursing homes meet Centers for Medicare and Medicaid Services requirements for facility-initiated discharges. In this proposed data brief, OIG will describe the sample of facility-initiated discharges they identified and examined in their ongoing work.
Conclusion
The general topics of opioids, patient harm events, and inappropriate nursing home discharges are not completely new to compliance professionals. However, these newly added Work Plan items demonstrate the new perspectives and approaches OIG is taking to ensure compliance.
If your organization is involved with any of these kinds of services, your compliance program should be proactive instead of reactive and review these newly highlighted areas on the OIG Work Plan.
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