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OIG October 2018 Work Plan Update

Health Law Alert

The OIG added five new items to its Work Plan in the October 2018 update: (1) childcare provider compliance with criminal background check requirements; (2) early results from Opioid State Targeted Response Grants; (3) Medicaid payments for services to incarcerated individuals; (4) roll-out of Medicare Beneficiary Identifiers; and (5) prescriptions of psychotropic and opioid drugs to foster children. Below are brief descriptions of the new items.

1. Review of State Monitoring of Criminal Background Check Requirements for Childcare Providers

The OIG will assess whether states have adequately monitored childcare provider compliance with criminal background check requirements mandated in the Child Care and Development Block Grant Act of 2014 (the CCDBG Act). The CCDBG Act requires that childcare providers submit to criminal background checks and mandates that states adopt policies and procedures to ensure provider compliance.

2. Reviewing States' First-Year Use of Opioid State Targeted Response Grants

The OIG will review states' early use of the Opioid State Targeted Response (Opioid STR) grants awarded by the Substance Abuse and Mental Health Services Administration (SAMHSA), authorized by the 21st Century Cures Act. The Opioid STR grant funds must be used for opioid treatment services using clinically appropriate evidence-based practices, and the OIG will evaluate the populations reached and the extent to which Opioid STR grant-funded treatment included medication-assisted treatment in the first year. The purpose of the Opioid STR grants, according to SAMHSA, is 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."

3. Identifying State Capitation Payments to Medicaid MCOs for Services to Prisoners

The OIG will review select states' payments to contracted Medicaid managed care organizations to determine whether those states made unallowable capitation payments on behalf of incarcerated individuals. States typically pay Medicaid managed care organizations a pre-set payment, known as a capitation payment, in exchange for providing or arranging for services to a Medicaid beneficiary. However, federal law does not allow federal financial participation for services provided to inmates, except when the inmate becomes an inpatient in a medical institution and is not in a prison setting.

4. Distribution and Implementation of Medicare Beneficiary Identifier

As part of the Medicare Access and CHIP Reauthorization Act of 2015, the Centers for Medicare & Medicaid Services (CMS) is replacing existing health insurance claim numbers with Medicare Beneficiary Identifiers (MBIs) in order to remove social security numbers from Medicare cards. The OIG will take three steps to evaluate controls in place related to the distribution and implementation of MBIs: (1) determine the number and nature of Medicare cards returned as undeliverable and evaluate the extent to which CMS tracks and follows up on these undeliverable cards; (2) assess CMS safeguards in place to protect MBIs; and (3) review payments to providers and determine whether Medicare cards deemed high risk and cards mailed and returned as undeliverable are being used inappropriately.

5. Evaluate State Oversight of Psychotropic and Opioid Prescriptions to Foster Children

The OIG will review states' use of the Comprehensive Child Welfare Information System (CCWIS) for monitoring prescriptions for psychotropic and opioid medications to children in foster care. States are required to have a plan for overseeing and coordinating health care services for foster children in order to receive certain federal funding, and CCWIS is a federally funded information system for state child welfare agencies to support case management for recipients of child welfare services. The OIG will also determine the extent to which the Administration for Children and Families ensures that children in foster care receive medications in accordance with state requirements.

Announced Agency Title Component Report Number(s)
October 2018 Administration for Children and Families Child Care and Development Fund: Provider Compliance with State Criminal Background Check Requirements Office of Audit Services W-00-18-20020
October 2018 Substance Abuse and Mental Health Services Administration Data Brief: Early Results from the Opioid State Targeted Response Grants Office of Evaluation and Inspections BL-18-00460
October 2018 Centers for Medicare & Medicaid Services Medicaid Capitation Payments Made on Behalf of Incarcerated Individuals Office of Audit Services W-00-18-31534; various reviews
October 2018 Centers for Medicare & Medicaid Services CMS Medicare Beneficiary Identifier Card Office of Audit Services W-00-18-35817
October 2018 Administration for Children and Families States' Use of the Child Welfare Information Systems to Monitor Medication Prescribed to Children in Foster Care Office of Audit Services W-00-18-59434; A-05-18-00007
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