Brief Summary of the OIG Work Plan Updates for July 2022
Some people have a condition called urinary retention. This means they are not able to voluntarily empty their urinary bladders. This results in urine being retained in the bladder, leading to urinary tract infections, bladder damage and kidney disease. The most common management for this condition is known as intermittent catheterization. This can involve catheterizing the urethra to drain the bladder and removing the catheter. This is typically repeated multiple times per day and utilizes what is known as an intermittent urinary catheter. This is contrasted with an indwelling urinary catheter that remains inserted for extended periods of time. Medicare paid more than $308 million for intermittent urinary catheters. The OIG reports previously identified high error rates for payments of urology supplies which included intermittent urinary catheters. These error rates were the result of not meeting Medicare requirements.
The OIG plans to audit Medicare payments for intermittent urinary catheters to determine whether claims submitted by DMEPOS suppliers complied with payment requirements. An example of such requirements includes the ability of a supplier to provide documentation from the physician or treating practitioner that indicates the urinary catheter is reasonable and necessary.
Opioid Use Annual Review
Prior to the COVID-19 pandemic, the country was dealing with an opioid crisis. Thousands were dying of overdoses each year. The COVID-19 pandemic did not make the opioid crisis disappear, but it complicated it. The U.S. HHS monitored opioid use during the COVID-19 pandemic and the OIG published a report titled “Opioid Use in Medicare Part D During the Onset of the COVID-19 Pandemic.” One of the key findings was that a total of 31,651 Medicare Part D beneficiaries had an opioid overdose in the first 8 months of 2020.
2021 data demonstrates the opioid crisis is still not over. According to the OIG, there were approximately 103,000 opioid-related overdose deaths in the United States in 2021. One way to deal with the crisis is to identify patients who might be at risk of overdosing. The OIG plans to create another report or data brief to provide information on opioid use among those enrolled in Medicare Part D in 2021. One of the OIG’s goals is to offer data from 2021 about the number of beneficiaries who received extreme amounts of opioids through Part D and those who appeared to be doctor shopping. The data brief will not stop there as it will also try to identify clinicians who might be prescribing outliers. Lastly, this OIG report should offer data on the number of Part D patients who are receiving drugs to treat opioid use disorder and drugs to reverse overdoses of opioids.
Vaccine Confidence Strategy
During the COVID-19 pandemic, many were anxiously awaiting the creation and availability of a vaccine. However, not everyone was willing to obtain the vaccine when it became available. Many individuals were hesitant or unwilling to be vaccinated. Some reports estimated vaccine hesitancy to be almost 50% and over 60% for some ethnic and racial groups.
The CDC’s program “Vaccinate with Confidence: Strategy to Reinforce Confidence in COVID-19 Vaccines” is designed encourage and instill confidence in the vaccine’s efficacy and safety. CDC defines "vaccine confidence" as the belief that vaccines work, are safe, and are part of a trustworthy medical system.
U.S. HHS announced the availability of $1 billion in supplemental funding for the CDC program with the hope that increased confidence in COVID-19 vaccines could lead to more adults, adolescents, and children getting vaccinated.
The CDC awarded various recipients, such as State and Tribal entities, a combined $250 million from the $1 billion in funding. Recipients were to use the awards for developing and implementing a vaccine confidence strategy, supporting efforts to build vaccine confidence, and conducting outreach to build trust in COVID-19 vaccines, the healthcare personnel who provide them, and the system that approves and distributes them. The funds could be used for television, radio and other media outreach as well as focused in-person activities on certain communities.
Like any government funding, this funding also comes with expectations. The OIG plans to conduct two audits of these financial awards. For the first audit, they would like to determine how much of each recipient's award has been spent, identify the best practices used and potential barriers recipients faced when spending the supplemental funds, and determine whether CDC provided oversight to recipients in developing and implementing a vaccine confidence strategy.
For the second audit, OIG will determine whether select recipients used the funding in accordance with Federal requirements and applicable award terms and conditions, and for underserved communities.
These newly added OIG Work Plan items are important for compliance professionals to be aware of. If your organization performs activities related to these OIG focus areas, it makes sense to perform some proactive auditing and monitoring of your own.
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