The OIG Releases New Work Plan Updates for Indian Health Services

The COVID-19 pandemic has been a struggle for all of us. However, COVID-19 has been particularly difficult for many Native Americans populations. It is not surprising then, that many of the OIG’s recent work plan items pertain to Indian Health Services, with a particular focus on COVID-19 issues. To better understand the specific challenges Native American populations have faced during the pandemic, let’s look at a few of the items the OIG has identified as potential risks for the population, programs that have been leveraged over the past year, and the potential audits of those programs to ensure their effectiveness.

Audit of Indian Health Service's Vaccines Distributed to Tribal Health Programs

As of December 2020, the American Indian and Alaska Native populations have an age-adjusted mortality rate from COVID-19 that is 1.8 times higher than the rate found among non-Hispanic whites, according to the Centers for Disease Control and Prevention (CDC). Obviously, the COVID-19 pandemic has affected these native populations more severely than others. The Indian Health Services (IHS) has a COVID-19 Pandemic Vaccine Plan that describes how they will distribute, allocate, and administer the vaccine. The CDC recommended that all jurisdictions be prepared to immediately vaccinate identified critical populations as the earliest COVID-19 vaccine doses became available and were granted emergency use authorization. IHS is recognized as a "coordinator," just like a State or other jurisdiction, for vaccine distribution. Indian health programs had the option to either receive vaccines through the IHS or their State. Approximately 338 facilities elected to receive vaccines through the IHS (including IHS direct facilities, Tribal Health Programs, and Urban Indian Organizations).

The OIG plans to focus this audit on IHS's coordination of the distribution, allocation, and administration of the vaccine to Tribal Health Programs. The objective of the audit is to determine whether IHS followed the Memorandum of Agreement for the CDC COVID-19 Federal Agency Vaccination Program and the IHS COVID-19 Pandemic Vaccine Plan to coordinate the distribution, allocation, and administration of the vaccines to Tribal Health Programs to protect American Indian and Alaska Native beneficiaries.

Performing the audit in this way will allow the OIG to review its priority area of promoting public health and safety with respect to services provided to the vulnerable populations served by IHS. It will also allow the OIG to address particularly critical goals that bear directly upon OIG's mission, and that are identified in the OIG Strategic Plan: Oversight of COVID-19 Response and Recovery.

These goals include protecting the health and safety of the American Indian and Alaska Native population that receives healthcare services through IHS programs, and identifying opportunities to increase the effectiveness of IHS's COVID-19 response. The work will include a review of policies and procedures that IHS had in place, and evaluate the measures implemented by Tribal Health Programs during Phases 1A and 1B of their vaccination programs. Specifically they will focus on the measures to distribute, allocate, and administer the COVID-19 vaccines developed by Pfizer-BioNTech and the Moderna—for the period of December 11, 2020, through February 28, 2021.

The OIG will select a sample of Tribal Health Programs to review, then they will identify best practices and challenges that Tribal Health Programs have faced when coordinating the distribution, allocation, and administration of COVID-19 vaccinations.

Indian Health Service Use of Critical Care Response Teams During the COVID-19 Pandemic

IHS is tasked with providing comprehensive healthcare for approximately 2.6 million American Indians and Alaska Natives, including ensuring safe and accessible healthcare during the COVID-19 pandemic.

In previous OIG work, they found that IHS facilities often lacked sufficient clinical staff. They also identified a number of problems caused by these staff shortages, including limited patient access to specialists, and problems with the use of contracted staff. The pandemic most likely worsened these shortages as IHS and Tribal hospitals continue to see more and more COVID-19 patients. In an attempt to solve this problem, IHS contracted additional staff by forming a Critical Care Response Team pilot program, which was created to provide urgent medical care for COVID-19 patients in facilities with low numbers of staff. IHS had deployed five teams to provide services at six IHS-operated facilities, and three tribally-operated facilities and planned to make the program a longer-term part of IHS operations. But problems identified in prior OIG work demonstrated that IHS may have had difficulty managing this contracted resource and integrating the teams into facility practices.

In this review, the OIG plans to use interviews with IHS and contracted staff, as well as document reviews, to determine if IHS use of the Critical Care Response Teams was efficient and appropriate.

Audit of the Distribution of Supplies in Response to COVID-19

As we’re all well  aware, COVID-19 has created unprecedented challenges for hospitals across the nation, including Indian Health Service (IHS), Tribal, and Urban Indian Health Program (UIHP) facilities. As mentioned previously, American Indians and Alaska Natives are particularly vulnerable to COVID-19 due to the relatively high rates of diabetes, cancer, heart disease, and asthma among these populations. These populations also tend to live in families that commonly share multigenerational homes. These strong family living arrangements can have great societal benefits but during a pandemic, maintaining physical distancing during a pandemic in such living conditions. To mitigate the spread of the disease in these multigenerational homes, IHS received funding for medical supplies and equipment through the COVID-19 relief bills allocated to IHS, Tribal, and UIHP facilities.

For this audit, the OIG plans to determine whether IHS had adequate internal controls to ensure that medical supplies and equipment were effectively distributed to the National Supply Service Center's customers in response to the COVID-19 pandemic.

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