Kusserow on Compliance: Breaking News: HHS OIG posts its mid-year Work Plan update


The Office of Inspector General (OIG) has posted a mid-year update on its Fiscal Year 2015 Work Plan, effective May 2015. It is worth reviewing, as it describes audits, evaluations, and certain legal and investigative initiatives that are ongoing, as well as those deleted, completed, postponed, or canceled. The OIG has added 20 new items that have been started since October 2014. For each project in the revised Work Plan, the agency included the subject, primary objective, criteria related to the topic, identification code for the review, and when it expects reports to be issued for the review. The update also forecasted areas for which it anticipates planning and/or beginning work in the upcoming fiscal year and beyond. These broader areas of focus are based on the results of OIG’s past work and have been identified as significant management and performance challenges facing HHS.

The OIG intends to continue reviews of the appropriateness of Medicare and Medicaid payments with possible additional work on the efficiency and effectiveness of payment policies and practices in inpatient and outpatient settings, for prescription drugs, and in managed care. Other areas it has under consideration include: (1) the integrity of the food, drug, and medical device supply chains; (2) security of electronic data; (3) use and exchange of health information technology; and (4) emergency preparedness and response efforts. It also plans to continue to focus on emerging payment, eligibility, management, and information technology systems security vulnerabilities in health care reform programs, such as the Health Insurance Marketplaces, as well as care quality and access in Medicare and Medicaid.

Among the new reviews schedule for Medicare and Medicaid program are the following:

  • Medicare outpatient payments for intensity-modulated radiation therapy (IMRT);
  • Hospital preparedness and response to high-risk infectious diseases;
  • Competitive bidding on beneficiary access to durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS);
  • Payments for the top 25 clinical diagnostic laboratory tests charged to Medicare;
  • Inpatient rehabilitation facility prospective payment system (IRF PPS) compliance, including required documentation to support claims paid by Medicare;
  • Accountable care organization (ACO) Medicare Shared Savings Program (MSSP) use of electronic health records (EHRs) to achieve their care coordination goals;
  • Medicare Part D billing trends, including changes in billing for commonly used opioid drugs;
  • States’ reporting of their federal share of Medicaid rebate collections;
  • Determinations of whether generic drug prices increased more than inflation for urban consumers;
  • Drug manufacturers’ treatment of sales of generics in their calculation of average manufacturer price (AMP) for the Medicaid drug rebate program; and
  • State submissions of Transformed Medicaid Statistical Information System (T-MSIS) data.

The OIG makes it clear that the Work Plan is constantly being updated and changed according to needs and circumstances and as such it does not provide status reports on the progress of the reviews, however it does periodically update the Work Plan.

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2015 Strategic Management Services, LLC. Published with permission.