OIG May 2019 Work Plan Updates

PUBLISHED: Jun 3, 2019
Relevant to: All Healthcare Organizations

The Office of the Inspector General (OIG) recently released updates to their work plan. In 2017, OIG transition from a yearly to a monthly Work Plan with the goal of enhancing transparency around OIG's continuous work planning efforts. The OIG Work Plan provides insight into areas where government enforcement and audit officials are focusing.

For May 2019, the following selection of OIG Work Plan activities are of interest to healthcare organizations:

Skilled Nursing Facility Adverse Event Screening Tool:

OIG developed the skilled nursing facility (SNF) adverse event trigger tool as part of its study, "Adverse Events in Skilled Nursing Facilities: National Incidence Among Medicare Beneficiaries" (OEI-06-11-00370), released in February 2014. The tool was developed with assistance from clinicians at the Institute for Healthcare Improvement (IHI), which also published the tool for industry use. This product will describe the purpose, use, and benefits of the SNF adverse event trigger tool and the guidance document released by IHI, including the methodology for developing the instrument and the instrument's use in developing the February 2014 report findings. It will also describe related guidance to providers issued by the Centers for Medicare & Medicaid Services. The goal of this product is to disseminate practical information about the tool for use by those involved with the skilled nursing industry. This review was announced in November 2016 and the expected issued date for this report is in 2019.

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. OIG will 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. OIG will also examine the factors that may either facilitate or hinder the provision of MAT in health centers.

Included with today’s StayAlert! Notice are example policies that may assist with identified audit/review areas.

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