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HHS Office of Inspector General Work Plan Update: News Items Added

July 23, 2020

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There are twelve OIG Work Plan updates released for July 2020, all of which are issued by the Office of Evaluation and Inspections, as well as the Office of Audit Services.

It is critical for providers, practices, and organizations alike to review these monthly updates to better assess their own deficiencies, take corrective actions, tighten up compliance policies, and ensure any future scrutiny by a government or commercial payor can be met with confidence and successful outcomes.

Please note items 1-4, and 11-12 are directly related to the COVID-19 pandemic.

  1. CDC's Collection and Use of Data on Disparities in COVID-19 Cases and Outcomes - The OIG will examine data that the Centers for Disease Control and Prevention (CDC) collects and maintains that can be used to assess racial, ethnic, and socioeconomic disparities in COVID-19 cases and outcomes. They will also examine CDC's lessons learned about how to best protect communities of color and economically disadvantaged communities in future public health emergencies. (expected issue date FY 2021)
  2. Geographic Distribution of Provider Relief Funds to Communities Disproportionately Impacted by Adverse COVID-19 Outcomes - The OIG will review the locations of hospitals that received Provider Relief Funds, with particular attention to hospitals located in communities of color and economically disadvantaged communities that were disproportionately impacted by adverse COVID-19 outcomes (i.e., hospitalization or death). (expected issue date FY 2021)
  3. Audit of CMS's Controls Over the Expanded Accelerated and Advance Payment Program Payments and Recovery - The OIG will provide details of the effectiveness of CMS controls over its Accelerated and Advance Payment Program (AAP) payments to providers and payment recovery. They will obtain data and meet with program officials to understand CMS's eligibility determination process for AAP payments and the steps CMS will have taken to recover such funds in compliance with the CARES Act and other Federal requirements. The OIG will also evaluate a select group of providers to determine whether they were eligible for AAP payments, and their efforts to repay CMS in compliance with the CARES Act and other Federal requirements. (expected issue date FY 2021)
  4. Medicaid: Expedited Provider Enrollment During COVID-19 Emergency - OIG's objective is to determine whether the State agency and providers complied with Federal and State requirements for newly enrolled providers under the national emergency declaration and if the State established tracking controls for these providers as well as giving providers adequate guidance on waived enrollment requirements under the SSA §1135 Authority to Waive Requirements during National Emergencies. (expected issue date FY 2021)
  5. Assessing Trends Related to the Use of Psychotropic Drugs in Nursing Homes - Previous OIG work found that elderly nursing home residents who were prescribed antipsychotic drugs—a type of psychotropic drug—were at risk for harm. CMS concurred with some OIG recommendations and developed new initiatives. There are continued concerns about whether CMS has made sufficient progress in reducing the use of antipsychotic drugs to care for the elderly. The OIG will report the changes over time for the following: (1) the use of psychotropic drugs for elderly nursing home residents; (2) citations and civil monetary penalties assessed to nursing homes regarding psychotropic drugs; and (3) the presence of diagnoses that exclude nursing home residents from CMS's measure of the use of antipsychotic drugs. (expected issue date FY 2021)
  6. Hospital Collection Effort for Medicare Bad Debt Basic Health Program Eligibility Determinations - The OIG plans to select a random sample of hospitals and review the policies and procedures in place related to collecting deductibles and coinsurance, offering financial assistance, identifying bad debt, and accounting for the receipt of previously reimbursed bad debt. They will also select a judgmental sample of claims with high-dollar bad-debt amounts (coinsurance or deductible) and determine how the hospitals adhered to Federal criteria in treating these bad debts. The audit will determine whether hospitals' policies and procedures for collecting Medicare deductible and coinsurance amounts from beneficiaries are in compliance with Federal regulations for the reimbursement of bad debt. (expected issue date FY 2021)
  7. Basic Health Program Eligibility Determinations - The OIG will determine whether States made Basic Health Program (BHP) payments on behalf of beneficiaries who did not meet Federal and State eligibility requirements. Section 1331 of the Affordable Care Act (ACA) gives States the option to create a BHP that provides health benefits coverage for low-income residents, citizens or lawfully present non-citizens, who would otherwise be eligible to purchase coverage through the Health Insurance Marketplace. The option also gives States the ability to provide more affordable coverage for these low-income residents and improve continuity of care for people whose income fluctuates above and below Medicaid and Children's Health Insurance Program levels. The BHP is funded primarily by Federal funds and must include 10 essential health benefits specified by the ACA. (expected issue date FY 2021)
  8. Biosimilar Trends in Medicare Part D - The OIG study will describe utilization and cost trends of biosimilars and reference biologics covered by Part D over time. In addition, they will determine how much Medicare and beneficiaries paid for biosimilars and reference biologics covered by Part D in 2019, and then compare those costs to determine how much Part D and beneficiaries would have spent with increased use of biosimilars. (expected issue date FY 2022)
  9. Beneficiary Cost-Sharing in Part D - The OIG's data brief will provide in-depth data on the amount beneficiaries pay out-of-pocket for Part D drugs. It will also determine the proportion of beneficiaries who have high cost-sharing and describe these beneficiaries and the drugs they commonly receive, including the proportion of drugs that are high cost. (expected issue date FY 2021)
  10. Analysis of New Rural Add-On Payment Methodology - Beginning in CY 2019, rural add-on payments were provided in varying amounts according to classification in one of three rural categories: (1) high utilization, (2) low population density, and (3) all other. The Bipartisan Budget Act of 2018 (BBA) requires home health claims to indicate the code for the county in which the home health service is provided. CMS has instructed providers to use value code 85 to report the county code and will return claims for correction when the code is missing or invalid. The OIG will perform an analysis of Medicare home health claims for CYs 2019 through 2021. They will trend the claim data and cost reports to determine what impact, if any, the new rural add-on methodology has had on home health agency providers and the utilization of home health services in rural areas. (expected issue date FY 2021)
  11. Use of Medicare Telehealth Services During the COVID-19 Pandemic - In response to the coronavirus disease 2019 (COVID-19) pandemic, CMS made a number of changes that allowed Medicare beneficiaries to access a wider range of telehealth services without having to travel to a health care facility. Although these changes are currently temporary, CMS is exploring whether telehealth flexibilities should be extended. These two concurrent reviews will be based on Medicare Parts B and C data and will examine the use of telehealth services in Medicare during the COVID-19 pandemic. Part I will examine the extent to which telehealth services are being used by Medicare beneficiaries, how the use of these services compares to the use of the same services delivered face-to-face, and the different types of providers and beneficiaries using telehealth services. Part II will identify program integrity risks with Medicare telehealth services to ensure their appropriate use and reimbursement during the COVID-19 pandemic. (expected issue date FY 2021)
  12. Centers for Medicare & Medicaid Services and States Implement Policy Modifications To Ensure That Medicaid Beneficiaries Continue To Receive Prescriptions - This audit will provide insights from State officials on action taken by States and DC to ensure Medicaid beneficiaries continue to receive prescriptions during the COVID-19 pandemic. The OIG will interview State officials from several States and DC to determine actions taken or planned. (expected issue date FY 2020)
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