Blog: OIG Releases September Work Plan Items; Includes Part D Sponsor Reporting of Rebates and Price Concessions to Medicare

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As we recently announced, the Office of Inspector General (OIG) is updating its Work Plan monthly rather than its previous twice-yearly publications. The September updates include 9 new Work Plan items:

  1. Federal Marketplace Enrollment Systems. OIG will assess operational readiness, internal controls, and IT security in preparation for the fifth open enrollment period.
  2. HHS Incident Response Capabilities. OIG will assess HHS’ policies and procedures for detecting, reporting, and responding to security incidents to determine whether HHS has sufficiently implemented incident response capabilities to safeguard the Department’s information technology systems and data.
  3. Availability of Behavioral Health Services in Medicaid Managed Care. This review of five States will determine the extent to which Medicaid managed care plans include behavioral health providers and whether enough providers are available to meet the needs of the Medicaid population.
  4. Medicaid Health Home Services for Beneficiaries with Chronic Conditions. OIG will review Medicaid health home programs for compliance with relevant Federal and State requirements related to treating beneficiaries with chronic medical conditions.
  5. Medicaid Nursing Home Life Safety Reviews. OIG will determine if LTC facilities that received Medicare or Medicaid funds complied with new Federal requirements for life safety and emergency preparedness for the period May 4, 2016 – November 15, 2017.
  6. SAMHSA Pre-Award Process for Opioid State Targeted Response Grants. OIG will review the process and criteria for awarding formula grants to States to determine whether SAMHSA followed HHS grant regulations and program-specific requirements when awarding Opioid State Targeted Response grants authorized under the 21st Century Cures Act.
  7. Review of Child Care and Development Fund Subsidy Payments in New York City. OIG will determine whether a State agency complied with Federal and State requirements when claiming reimbursement for childcare subsidy program payments.
  8. Part D Sponsors Reporting of Direct and Indirect Remunerations. OIG will determine whether Part D sponsors complied with Medicare requirements for reporting direct and indirect remunerations (DIR), such as all rebates, subsidies, and other price concessions from all sources, including, but not limited to, manufacturers and pharmacies, that decrease the costs incurred by Part D sponsors for Part D drugs.
  9. Child Care and Development Fund: State Criminal Background Check Requirements. OIG will determine States’ progress toward implementation of criminal background check requirements established under the Child Care and Development Block Grant Act of 2014 and identify best practices that States can use in implementing these requirements.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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