The Department of Health and Human Services (HHS) Office of Inspector General (OIG) announced several new changes in its Work Plan update for October 2023. The OIG Work Plan forecasts the projects that OIG plans to implement over the foreseeable future. These projects usually include OIG audits and evaluations. Below are the highlights from the Work Plan update of which providers and suppliers should take notice.
First, OIG will perform an audit of the Morehouse School of Medicine’s National Infrastructure for Mitigating the Impact of COVID-19 (NIMIC) initiative. The NIMIC initiative is a 3-year, $40 million cooperative agreement between HHS’s Office of Minority Health and the Morehouse School of Medicine to fight COVID-19 in racial and ethnic minority, rural, and socially vulnerable communities. The Morehouse School of Medicine is leading the initiative to coordinate a strategic network to deliver COVID-19 related information to communicates hit hardest by the pandemic.
Second, OIG will audit the accuracy of the Child Care and Development Fund (CCDF) attendance records at Minnesota child care centers. The CCDF is the primary federal funding source devoted to subsidizing the child care expenditures of low-income families. OIG has stated that it identified issues with the completeness and accuracy of child care attendance records and with related billings for child care services. Minnesota, as well as possibly additional states, have been selected by OIG for a review to determine whether the state(s) complied with federal and state requirements related to attendance records and whether payments for services at child care centers were allowable.
Third, OIG plans to audit efforts of state agencies to ensure the safety of children in foster care. The Federal Foster Care Program, which is administered at the federal level by the Administration for Children and Families, helps states provide safe and stable out-of-home care for children. OIG announced that it plans to conduct two nationwide audits with differing focuses. In the first audit, OIG will examine the states’ use of temporary emergency placements not designated to house children, such as hotels or offices, when a permanent placement is unavailable. The second audit seeks to determine whether critical incidents involving serious physical injury or sexual abuse to a child in foster care are being reported in accordance with federal and state requirements.
Finally, OIG will conduct an evaluation to assess whether children enrolled in Medicaid and the Children’s Health Insurance Program (CHIP) who had an emergency department visit or hospitalization for a suicide attempt or intentional self-harm incident received timely mental health follow up care within established timeframes. OIG plans to examine whether certain groups of children in the nation’s population were less likely to receive timely mental health follow up care after a hospitalization or emergency department visit.
For over 35 years, Wachler & Associates has represented healthcare providers and suppliers nationwide in a variety of health law matters, and our attorneys can assist providers and suppliers in understanding new developments in healthcare law and regulation. If you or your healthcare entity has any questions pertaining to OIG reviews, Medicare audits, or healthcare compliance, please contact an experienced healthcare attorney at 248-544-0888 or wapc@wachler.com.