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OIG Adds Five New Work Plan Items in October.

The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently issued five updates to its Active Work Plan (Work Plan) for October.  The Work Plan outlines ongoing and planned audits and evaluations for the fiscal year and beyond.  The OIG releases the Work Plan items on a monthly basis to enhance the transparency of its work planning efforts.  A monthly update schedule more closely aligns with the OIG’s work planning process, which anticipates and responds to emerging issues.  Work Plan items span across HHS agencies and cover the Centers for Medicare & Medicaid Services (CMS), public health agencies such as the Centers for Disease Control and Prevention and National Institutes of Health, and human resources agencies such as the Administration for Children and Families (ACF) and the Administration on Community Living.  The OIG considers various factors when developing its Work Plan items, including legal mandates, congressional requests, budgetary concerns, potential for positive impact, and other considerations.

The October additions to the OIG Work Plan include the following:

  1. States’ Use of the Child Welfare Information Systems To Monitor Medication Prescribed to Children in Foster Care.
  • State child welfare agencies use the Comprehensive Child Welfare Information System (CCWIS) to support case management for children and families receiving child welfare services. Children in foster care receive child welfare services and may be prescribed psychotropic and opioid drugs.  Psychotropic medications are prescribed to treat mental health disorders such as schizophrenia, depression, bipolar disorder, anxiety disorders, and attention deficit/hyperactivity disorder.  Opioids are also prescribed to manage pain surgery, injury, or illness, but are considered high risk for misuse and abuse.  States must have a plan to oversee and coordinate health care services for children placed in foster care, including having protocols for appropriately using and monitoring medications.  The ACF oversees states’ foster care programs.  The Office of Audit Services (OAS) will review states’ use of the CCWIS for monitoring foster care children’s psychotropic and opioid medication prescriptions.   The review will also determine the extent to which ACF ensures foster care children receive medications in accordance with state requirements.
  1. CMS Medicare Beneficiary Identifier Card.
  • Under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), CMS is required to remove Social Security Numbers from Medicare cards. Consequently, CMS has implemented the Medicare Beneficiary Identifier (MBI) to replace the existing health insurance claim number.  The OAS will conduct a series of reviews to assess the MBI controls that are in place.  These reviews will determine the number and nature of Medicare cards returned as undeliverable.  It will also determine the extent to which CMS tracks and follows up on the undeliverable Medicare cards.  The series of reviews will further assess the safeguards CMS has in place to protect the MBI.  In addition, CMS will perform a review of payments to providers to determine if Medicare cards deemed high risk and returned as undeliverable are being used for inappropriate items and services.
  1. Medicaid Capitation Payments Made on Behalf of Incarcerated Individuals.
  • States contract with Medicaid managed care organizations, usually for a predetermined periodic payment known as a capitation payment, to provide specific services to enrolled Medicaid beneficiaries. However, federal financial participation is not available to services provided to inmates of public institutions according to Section 1905 of Title XIX of the Social Security Act, 42 CFR § 435, and CMS guidance, unless the inmate is not in a prison setting and becomes an inpatient in a medical institution.  The OAS will conduct a review to determine whether certain states made unallowable capitation payments to Medicaid managed care organizations on behalf of incarcerated individuals.
  1. Data Brief: Early Results from the Opioid State Targeted Response Grants.
  • The 21st Century Cures Act authorized the Substance Abuse and Mental Health Services Administration (SAMHSA) to award and oversee $1 billion in Opioid State Targeted Response (Opioid STR) grants. The purpose of the Opioid STR grants are to “address the opioid crisis by increasing access to treatment, reducing unmet treatment need, and reducing opioid overdose related deaths through the provision of prevention, treatment and recovery activities for opioid use disorder.”  A majority of grant funds must be used for opioid treatment services that use clinically appropriate, evidence-based practices, specifically the use of medication assisted treatment.  The Office of Evaluation and Inspections will produce a data brief on the early results of the Opioid STR grants.  The brief will describe states’ use of grant funds for the program’s first year, specifically describing the populations the grant funds reached and the extent to which medication assisted treatment was utilized from the grant funds.
  1. Child Care and Development Fund: Provider Compliance with State Criminal Background Check Requirements.
  • The Child Care Development Fund (the Fund), which was reauthorized in the Child Care and Development Block Grant Act of 2014 (CCDBG Act), is the primary source of federal childcare cost subsidies for low-income families. The CCDBG Act requires criminal background checks for all licensed, regulated, and registered childcare providers, including all childcare providers eligible to deliver childcare services.  States are also mandated to have policies and procedures in place that meet the criminal background check requirements.  The OAS will assess provider compliance with each state’s criminal background record check requirements to determine whether states’ monitoring processes ensure childcare providers are in compliance with criminal background check requirements established under the CCDBG Act.

The OIG Work Plan is available at: