Deeper Than the Headlines: New Items Added to the OIG Work Plan (March 2018)

The OIG has added seven new items to their work plan in March 2018. Let’s look at a few of them a little more closely.

Data Brief: Opioid Use in Medicare Part D

Any compliance professional who has been reading the most recent enforcement headlines in the healthcare compliance community has noticed a pronounced uptick in the cases surrounding opioids. Most of those cases highlight how health care providers are involved in “pill mills” or other schemes contributing to the opioid epidemic in the country.

This OIG work plan item will focus on identifying patients who are at risk of overdose or abuse as the OIG feels this is key to addressing this crisis. The data brief will provide updated data on Part D spending for opioids and the number of beneficiaries that received extreme amounts of opioids through Part D and those who appear to be "doctor shopping."

The Incidence of Adverse Events in Indian Health Service Hospitals

In the OIG’s Video Series, “Eye on Oversight,” they frequently highlight general areas of compliance concern. In November of 2016, the series of videos highlighted challenges in Indian Health Service Hospitals. This new work plan addition stays on that theme by focusing on adverse events in those hospitals.

According to the OIG, the Indian Health Service operates 26 hospitals that provide free inpatient care to eligible American Indians and Alaska Natives. Many of these hospitals are located in remote areas and have low average daily patient censuses. The OIG plans to identify adverse and temporary harm events at IHS hospitals in FY 2017. They will estimate the incidence and preventability of these events by reviewing medical records associated with a sample of inpatient stays in IHS hospitals. They will also assess the extent to which IHS hospitals recorded these events in their incident reporting systems.

Financial and Administrative Review at Indian Health Service Area Offices

In addition to the item above about adverse event at IHS hospitals, the OIG also plans to look at other HIS issues such are a financial and administrative review at HIS area offices.

OIG states the IHS provides health services to approximately 2.2 million American Indians and Alaska Natives in 567 federally recognized Tribes located in 35 States. These services are funded through annual appropriations distributed among IHS headquarters offices and 12 regional offices called Area Offices. These services are provided through IHS and Tribal facilities that operate (1) IHS direct health care service programs, (2) tribally operated health care service programs authorized under Titles I and V of the Indian Self-Determination and Education Assistance Act and (3) Urban Indian Health Program services and resource centers. Congress has expressed concern about IHS's administrative and financial management of program funds. OIG will examine how an IHS Area Office monitors and allocates appropriations received from IHS headquarters offices within its geographic area. They will also examine an Area Office with respect to accounting for IHS annual appropriations and allocating IHS appropriations to service units within the Area Office's geographic area.

Grantee Compliance With Cost Principles for Organizations With Multiple HHS Discretionary Funding Sources

If you’re a regular reader of our blogs you’ll notice over the last couple months, we’ve posted about compliance issues associated with grants (see Feb. 19, 2018, post and Jan. 8, 2018 post).

The OIG continues their oversight work as it relates to grants by adding this new item to their work plan. Specifically, they will look at how well grantees are maintaining compliance with the required cost principles associated with grants.

According to the OIG, grantees must maintain financial management systems that contain written procedures for determining the reasonableness, allocability, and allowability of costs in accordance with applicable Federal cost principles and the terms and conditions of the award. Grantees also must maintain accounting records that are supported by source documentation and financial management systems that provide for accurate and complete disclosure of the financial results of each project or program sponsored by HHS. OIG will review select grantees receiving HHS grant funding from multiple sources to determine whether they are allocating and claiming costs in accordance with Federal requirements. They will also review procedures in place for HHS oversight and coordination between the participating grant programs.

These are just a few of the recent additions to the OIG Work Plan posted in March 2018. Subscribe to our blog so you are keeping up to date on the latest compliance issues.