Deeper Than the Headlines: October 2018 OIG Work Plan Additions

It’s time to share the updates to the OIG Work Plan. The following items were added to the work plan in October 2018.

Opioids

Consistent with the attention we’ve called to the increased enforcement efforts in opioid abuse, the OIG has added a work plan item to share a data brief describing the early results from the opioid state targeted response grants.

The 21st Century Cures Act authorized $1 billion in Opioid State Targeted Response (Opioid STR) grants, to be awarded and overseen by the Substance Abuse and Mental Health Services Administration (SAMHSA). As described by SAMHSA, the purpose of these grants is to "address the opioid crisis by increasing access to treatment, reducing unmet treatment need, and reducing opioid overdose-related deaths through the provision of prevention, treatment and recovery activities for opioid use disorder." Most funds must be used for opioid treatment services using clinically appropriate evidence-based practices, particularly the use of medication-assisted treatment. The OIG plans to review early results of the Opioid STR grants. The data brief will describe States' use of Opioid STR grant funds in the first year of the program, including the populations reached and the extent to which Opioid STR grant-funded treatment included medication-assisted treatment.

CMS Medicare Beneficiary Identifier Card

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires CMS to remove Social Security Numbers from Medicare cards and, as a result, CMS is replacing the existing health insurance claim number with a Medicare Beneficiary Identifier (MBI). OIG will conduct a series of reviews to assess controls in place to distribute and implement usage of the MBI.

They will:

1. determine the number and nature of Medicare cards returned as undeliverable and the extent to which CMS tracks and follows up on Medicare cards returned as undeliverable
2. assess CMS's safeguards in place to protect the MBI
3. conduct a review of payments to providers to determine whether Medicare cards deemed high risk and cards mailed and returned as undeliverable are being used for inappropriate items and services.

Provider Compliance with State Criminal Background Check Requirements

Reauthorized in the Child Care and Development Block Grant Act of 2014 (CCDBG Act), the Child Care and Development Fund is the primary source of Federal subsidies of childcare costs to low-income families. All licensed, regulated, and registered childcare providers, as well as all childcare providers eligible to deliver childcare services, are subject to the CCDBG Act's requirements for criminal background checks. The CCDBG Act mandates that a State have policies and procedures in place that meet the criminal background check requirements. To determine whether the States' monitoring process has ensured compliance by childcare providers with States' requirements for criminal background checks established under the CCDBG Act, OIG will assess provider compliance with the criminal background record check requirements that have been established by each State.

States' Use of the Child Welfare Information Systems to Monitor Medication Prescribed to Children in Foster Care

Psychotropic and opioid drugs are among those that may be prescribed to children in foster care. Psychotropic medications treat mental health disorders such as schizophrenia, depression, bipolar disorder, anxiety disorders, and attention-deficit/hyperactivity disorder. Prescription opioids include narcotics to manage pain from surgery, injury, or illness and have a high risk of abuse and misuse.

To receive certain Federal funding for child welfare services, States are required to have a plan for overseeing and coordinating health care services for any child in foster care placement, including protocols for the appropriate use and monitoring of medications. The Comprehensive Child Welfare Information System (CCWIS) is a federally funded information system for State child welfare agencies to support case management for children and families receiving child welfare services.

OIG will review States' use of the CCWIS for monitoring psychotropic and opioid medications prescribed to children in foster care. Because the Administration for Children and Families (ACF) oversees States' foster care programs, OIG will also determine the extent to which ACF ensures that children in foster care receive medications in accordance with State requirements.

As always, make sure to proactively check these areas within your organizations if these types of services are provided by your organization.