Don’t Miss These OIG Work Plan Updates for July and August!

Ah, Summer! The time to get outside, find new ways to entertain your pets or your kids, or take a vacation with your family or friends. Summer is often synonymous with travel and a little break from the daily grind. But do you know who doesn’t take a summer vacation? The OIG. They’ve recently added some items to their Work Plan in July and August that you’re going to want to check out to ensure your compliance program stays current on the OIG’s efforts. Let’s look at some of the highlights.

Emergency Communication Plans for Home Health Agencies

The COVID-19 pandemic has resulted in a spotlight on health care organization’s preparedness for emerging infections disease. Home Health Agencies (HHA) have been significantly affected. The OIG has ongoing work reviewing HHA preparedness for emerging infectious diseases, but that is not the only type of emergency for which HHAs need to be prepared. Natural disasters such as hurricanes, floods, and fires threaten healthcare operations, even as HHAs continue to deal with COVID-19.

According to the OIG, the United States experienced a record number of natural disasters in 2020. Many scientists expect an even greater number of hurricanes and storms in 2021. Past natural disasters have exposed vulnerabilities in HHAs' preparedness for disasters, specifically regarding communication and continuity of care. HHAs must comply with CMS Emergency Preparedness Conditions of Participation (EP CoPs). Specifically, CMS requires HHAs to create communication plans that include information necessary to ensure continuity of care during any emergency. This OIG Work Plan evaluation will determine whether selected HHAs' complied with EP CoPs.

Diversity of Enrollees in Clinical Trials

Ensuring an appropriate representation of certain racial and ethnic minorities, women, and individuals of all ages in clinical trials have been a concern for many years. This concern has been highlighted with recent attention due to the COVID-19 pandemic's disproportionate impact on minority populations. While offering over $31 billion (about $95 per person in the US) in funding, the National Institutes of Health (NIH) is the largest contributor of biomedical and public health research. With this significant financial support in mind, the NIH is responsible for reviewing progress reports that document grantees' progress toward NIH-approved enrollment plans, which may include a diversity and inclusion component.

This OIG study will examine how NIH monitors and ensures enrollment of racial and ethnic minorities, women, and individuals of all ages within the clinical trials it funds and its actions in response to clinical trials that are not meeting approved enrollment plans. It will also discover and report any challenges grantees face as they try to meet their commitments to inclusive enrollment in their clinical trials.

CDC’s REACH Program

The Racial and Ethnic Approaches to Community Health (REACH) program is administered by the CDC. It is responsible for awarding monies to State and local health departments, tribes, universities, and community-based organizations to improve health, prevent chronic diseases, and reduce health disparities among racial and ethnic populations with the highest risk of chronic disease.

For example, in fiscal year 2018, the CDC awarded $125.5 million in REACH funds to 31 recipients for a 5-year project period beginning September 30, 2018, with 1-year awards averaging $780,000 per recipient. The recipients of these grants are responsible for working with communities to reduce health disparities among racial and ethnic populations with the highest burden of chronic disease (e.g., heart disease, type 2 diabetes, and obesity). The program offers custom interventions to address preventable risk behaviors, such as tobacco use, poor nutrition, and physical inactivity.

REACH grant recipients must work with specific prioritized populations such as African Americans, Hispanic Americans, Asian Americans, Native Hawaiians/Other Pacific Islanders, and American Indians/Alaska Natives. Awardees are also required to work in certain areas such as tobacco, nutrition, physical activity, and community-clinical linkages and the accompanying activities to improve conditions for better health.

The OIG plans to determine whether selected REACH grant recipients used their funding following Federal requirements and grant terms. Specifically, OIG plans to audit REACH program funds awarded to the selected recipients to ensure that REACH program funds were used for their intended purposes and met the needs of priority populations.

Grant Funding for Substance Abuse Prevention and Treatment

The Substance Abuse and Mental Health Services Administration's (SAMHSA's) Substance Abuse Prevention and Treatment Block Grant (SABG) program is the most extensive Federal program dedicated to improving publicly funded substance abuse prevention and treatment systems.

Through the program, all 50 States, the District of Columbia, and U.S. Territories receive funding to prevent and treat substance abuse. Federal requirements for the SABG program include fiscal control and accounting procedures to a level that allows for the tracing of funds adequate to establish that such funds were not used in violation of block-grant restrictions and statutory prohibitions (45 CFR § 96.30).   The OIG will examine whether the States' SABG expenditures for subrecipients, including spending for contracted transitional housing providers, complied with Federal and State requirements.

Conclusion

If your organization is involved in any of the programs or activities described above, it’s crucial to assess your risk in these areas and perform proactive audits or reviews like what the OIG is proposing.

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