Work Plan Additions for May 2019
For May 2019, there are only two OIG Work Plan additions. The first involving the accuracy of drug manufacturers quarterly pricing data, and the second is regarding access to medical-assisted treatment at health centers.
Accuracy of Drug Manufacturers' Quarterly Pricing Data
CMS uses manufacturer-reported average sales price (ASP) and average manufacturer price (AMP) data to calculate Medicaid rebate amounts and Part B drug reimbursements. When these data are not accurate, CMS and States might not set appropriate reimbursement or rebate amounts for drugs. This can result in CMS, States, and Medicare beneficiaries paying more for these drugs. The Social Security Act provides a mechanism for monitoring market prices and limiting potentially excessive ASP-based payment amounts by requiring the OIG to compare ASPs with AMPs. As part of this comparison, each quarter OIG manually reviews publicly available documentation from manufacturers' websites and other sources, as appropriate, to validate the drug product and pricing information for selected national drug codes (NDCs). OIG may correct data associated with certain NDCs or exclude certain drug codes from the quarterly comparison if it identifies potential errors or inconsistent data. This study will determine the number of NDCs reported to CMS by manufacturers that contained potential errors in ASP and/or AMP data as well as the number of drug codes excluded from quarterly comparisons because of potential errors in the manufacturers' data.
Access to Medication-Assisted Treatment at Health Centers
Medication-assisted treatment (MAT) is a significant component of the treatment protocols for opioid use disorder and plays a large role in combating the opioid epidemic in the United States. Congress has taken sustained action to support MAT services through broadened prescribing authorities, increased Federal funding, and enhanced insurance protections. However, a treatment gap continues to exist where less than 1 percent of the people in the United States who need treatment for substance use disorder receive it. OIG will examine access to MAT through health centers funded by the Health Resources and Services Administration (HRSA).
Health centers are key entities to expand access to MAT because they provide both primary care and behavioral healthcare services and accept patients regardless of their ability to pay. Additionally, in recent years, HRSA has awarded grant funding specifically to expand access to substance use disorder treatment at health center sites. The OIG plans to examine how many health centers provide MAT services, what types of services they provide (e.g., specific medications, behavioral health services such as counseling), how many of their providers are waivered to prescribe MAT drugs, and how many patients they are treating with MAT. They will also examine the factors that may either facilitate or hinder the provision of MAT in health centers. Video Recording of Joanne M. Chiedi, Principal Deputy Inspector General’s HCCA remarks in a recent blog post I briefly summarized the April 2019 HCCA Compliance Institute’s keynote speaker’s remarks of Joanne M. Chiedi, Principal Deputy Inspector General, Office of Inspector General, Department of Health and Human Services. Though I tried my best to sum up her remarks for those who were unable to attend, the OIG has now posted the recording in this 22-minute video and can be found here.
CJ Wolf
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