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OIG July 2018 Work Plan Update

Health Law Alert

The OIG added six new items to its Work Plan in the July 2018 update. Areas addressed include HHS cybersecurity vulnerabilities, increased payments for transfer claims with outliers, oversight of funds for Access Increases in Mental Health and Substance Abuse Services (AIMS), post-operative services provided in the global surgery period, oversight of accreditation bodies for opioid treatment programs and outpatient three-dimensional conformal radiation therapy planning service.

Identification of HHS Cybersecurity Vulnerabilities

The OIG will perform information technology audits of the HHS Office of the Secretary and its operating divisions to identify cybersecurity vulnerabilities that could potentially compromise their systems and networks.

Increased Payments for Transfer Claims with Outliers

The transfer rule reduces Diagnosis Related Group (DRG), Disproportionate Share Hospital (DSH), and Indirect Medical Education (IME) payments; however, the outlier methodology at 42 C.F.R. § 412.80(b) can lead to higher outlier payments for transfer cases. The OIG plans to review and report on whether such increased outlier payments negate the DRG, DSH, and IME payment reductions for these cases.

HRSA's Oversight of Funds for Access Increases in Mental Health and Substance Abuse Services (AIMS)

The Health Resources and Services Administration (HRSA) administers Access Increases in Mental Health and Substance Abuse Services (AIMS) grants to health centers that are intended to expand access to mental health and substance abuse services, with a focus on the treatment, prevention, and awareness of opioid abuse. The OIG will review HRSA's internal controls to determine whether they are appropriate for awarding AIMS grants and monitoring AIMS grant recipients.

Review of Post-Operative Services Provided in the Global Surgery Period

The OIG will review post-operative services for a sample of global surgeries to verify the accuracy of the data collected by CMS under Section 523 of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The OIG seeks to determine whether the number of post-operative visits has been reported accurately and whether global surgery fees reflect the actual number of post-operative services provided during the global surgery period.

SAMHSA's Oversight of Accreditation Bodies for Opioid Treatment Programs

The OIG will conduct audits of accrediting bodies that have been approved to evaluate opioid treatment programs (OTPs) by the Substance Abuse and Mental Health Services Administration (SAMHSA). These audits will be directed at determining if SAMHSA is providing effective oversight in compliance with federal requirements for evaluating these bodies, including SAMHSA's regulations set forth at 42 C.F.R. Part 8.

Review of Outpatient Three-Dimensional Conformal Radiation Therapy Planning Services

Three-Dimensional Conformal Radiation Therapy (3D-CRT) is a radiation therapy technique that allows doctors to sculpt radiation beams to the shape of a patient's tumor. Medicare allows payment for separately billed radiation planning services for 3D-CRT if they are billed on a different date of service than the treatment plan. However, Medicare will not pay for separately billed planning services for similar forms of radiation. The OIG will assess the amount of potential savings to Medicare if radiation planning services for 3D-CRT were subject to the same requirements as similar services and not separately billable.

Announced Agency Title Component Report Number(s)
July 2018 All STAFFDIV/OPDIVs Identification of HHS Cybersecurity Vulnerabilities Office of Audit Services W-00-18-42021; W-00-18-42022
July 2018 Centers for Medicare & Medicaid Services Increased Payments for Transfer Claims with Outliers Office of Audit Services W-00-18-35814
July 2018 Health Resources & Services Administration HRSA's Oversight of Funds for Access Increases in Mental Health and Substance Abuse Services (AIMS) Office of Audit Services W-00-18-59439
July 2018 Centers for Medicare & Medicaid Services Review of Post-Operative Services Provided in the Global Surgery Period Office of Audit Services W-00-18-35810
July 2018 Substance Abuse and Mental Health Services Administration SAMHSA's Oversight of Accreditation Bodies for Opioid Treatment Programs Office of Audit Services W-00-18-59035
July 2018 Centers for Medicare & Medicaid Services Review of Outpatient Three-Dimensional Conformal Radiation Therapy Planning Services Office of Audit Services W-00-18-35812

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