OIG Work Plan Monthly Review: September 2017

Many of the 12 new items that the OIG added to its 2017 Work Plan in September target state and federal government agencies, including the Department of Health and Human Services itself—specifically, whether HHS’s incident response measures are adequate to safeguard the agency’s IT systems and data from cyber threats and attack. While none of the new items specifically or address lab tests, three might affect labs indirectly.

1. Medicaid Nursing Home Life Safety Reviews

Concern: CMS recently changed its life safety and emergency preparedness rules health care facilities by requiring long term care facilities to install expanded sprinkler and smoke detector systems and implement an emergency preparedness plan that includes sheltering in place for residents who cannot evacuate during emergencies.

What OIG Will Investigate: The OIG will review whether long term care facilities are complying with these requirements.

2. Part D Sponsors Reporting of Direct and Indirect Remuneration

Concern: Medicare calculates certain payments to sponsors based on amounts sponsors actually paid, net of direct and indirect remuneration (DIR). DIR includes all rebates, subsidies and other price concessions from manufacturers, pharmacies and other sources. Part D sponsors must submit their DIR reports to CMS for use in the payment reconciliation process.

What OIG Will Investigate: The OIG will determine whether Part D sponsors are complying with DIR reporting requirements.

3. Controls Over Opioid Treatment Programs

Concern: The OIG has recommended that SAMHSA (the Substance Abuse and Mental Health Services Administration) require hospitals and pharmacies that receive funds opioid treatment program funds from State agencies via the Substance Abuse Prevention and Treatment Block Grant program to implement stronger security protocols to reduce thefts of opioids. Opioid abuse is a compelling public health concern, and in We established under 42 CFR Part 8. We will also determine whether program expenditures are allowable in accordance with Federal requirements outlined in 45 CFR Part 75, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards

What OIG Will Investigate: The OIG will determine whether a State agency is effectively monitoring its opioid treatment programs’ services and medications in accordance with the federal guidelines for opioid treatment programs.

Takeaway: Although none of the new OIG initiatives directly involve lab services, you need to be aware of them if you’re involved in providing any of the affected goods and services to Medicare, Medicaid or other government health program beneficiaries.