Principal Deputy Inspector General Grimm’s Speech On OIG’s Top 10 Priorities

King & Spalding

[author: Christopher Jew]

On April 19, 2021, HHS OIG Principal Deputy Inspector General Christi A. Grimm gave the keynote address at the Health Care Compliance Association’s 25th Annual Compliance Institute wherein she highlighted 10 key compliance priorities that will drive much of OIG’s work in the coming year and beyond. While these priorities do not represent OIG’s full work plan and there are other core areas OIG is focused on, the compliance priorities include: (1) Overseeing COVID-19 Relief and Response; (2) Realizing the Potential of Telehealth (3) Ensuring Quality of Care and Patient Safety in Nursing Homes; (4) Advancing Health Equities; (5) Modernizing Program Integrity and Compliance Information; (6) Combating the Substance Use Disorder Epidemic; (7) Prioritizing Cybersecurity; (8) Information Blocking Enforcement; (9) Implementing Value-Based Care; and (10) Strengthening Managed Care Program Integrity.

Principal Deputy Inspector General Grimm did not have time to discuss all 10 OIG priorities, but she did provide additional information regarding the following 5 compliance priorities:

  • Overseeing COVID-19 Relief and Response – Audits, evaluations, and investigations examining the COVID response will remain a priority for OIG. OIG is currently conducting 57 audits and evaluations related to COVID-19 and has issued eight reports to date.
  • Realizing the Potential of Telehealth – Telehealth can be a tool for providers to help address patient access issues, especially for underserved populations. Effectively expanding telehealth and ensuring program integrity will take effort on a number of fronts that may not be considered traditional compliance issues: cybersecurity, interoperability, and patient access to technology. Last month, OIG issued a message regarding telehealth based on its current knowledge.
  • Ensuring Quality of Care and Patient Safety in Nursing Homes – OIG is focused on protecting residents from abuse, neglect, and failures of care, improving state oversight, and improving quality of care monitoring. To support this effort, OIG conducted an outreach campaign aimed at protecting nursing home residents at 493 nursing homes.
  • Advancing Health Equities – OIG acknowledges that the COVID-19 pandemic highlighted the preexisting stark racial and socioeconomic disparities with regards to health outcomes. OIG’s work will utilize an equity lens to better achieve equity in health and human services, including areas such as quality of care, access to care, and health outcomes.
  • Modernizing Program Integrity and Compliance Information – OIG anticipates a multiyear effort to modernize OIG guidance, compliance resources, and data sharing practices to make program integrity and compliance information easier to access. During the COVID-19 pandemic, OIG worked with organizations that needed extensions of deadlines by providing flexibilities for 42 self-disclosure actions, 81 Corporate Integrity Agreements, and 20 payment extensions in civil monetary penalty cases. OIG anticipates continuing some of these practices going forward.

The text of Principal Deputy Inspector General Grimm’s speech is available here, the presentation is available here, and the handout for the speech is available here.

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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