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The OIG Strategic Plan for Response and Recovery During COVID-19

June 09, 2020
Documentation, Billing, & Coding By Deborah Alexander, Director

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) released an update to their strategic plan, specific to the Coronavirus Disease (COVID-19).

 

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The OIG unveiled four goals which will drive their mission for assessing HHS’ COVID-19 response and recovery. These four goals are: Protect People, Protect Funds, Protect Infrastructure and Promote Effectiveness. To achieve these goals, the OIG is using risk assessments and data analytics to identify, monitor and target potential fraud, waste, and abuse. Suspicious activities and billing patterns are under audit by the OIG experts using modern tools and technologies, including artificial intelligence to strengthen their oversight and enforcement.  

Here is the statement from the OIG:

“OIG is using risk assessment and data analytics to identify, monitor, and target potential fraud, waste, and abuse affecting HHS programs and beneficiaries and to promote the effectiveness of HHS’s COVID-19 response and recovery programs We use expert staff and modern tools and technologies, including artificial intelligence, to detect trends and patterns of suspicious activity, and to shape and strengthen our oversight and enforcement. As appropriate and feasible, we share data analytics and technical assistance with HHS officials to strengthen program integrity, effectiveness, and management practices. Further, we are coordinating our work with key oversight and law enforcement partners, including the Pandemic Response Accountability Committee (PRAC); Federal, State, local, and Tribal entities; and the Government Accountability Office, among others, to ensure adequate oversight, avoid duplication, and share insights.”

For more information, read the “OIG Strategic Plan: Oversight of COVID-19 Response and Recovery.”

Let us review the OIG goals more closely.

Goal 1:Protect the People

The HHS has a responsibility to protect the health and safety of people, this includes public health and beneficiaries. The OIG provides oversight to ensure that HHS efforts to protect people are effective. 

Three objectives were reported:

  1. Objective A: Assist in and support ongoing COVID-19 response efforts while maintaining independence.
  2. Objective B: Fight fraud and scams that endanger HHS beneficiaries and the public. The priority is assessing cases where patient harm is a concern and report those that are.
  3. Objective C: Assess the impacts of HHS programs on the health and safety of beneficiaries and the public. Part of this objective is to conduct audits and evaluations in various settings, such as skilled nursing homes. The focus of these audits and evaluations are on the health and safety of the beneficiaries.

Goal 2:Protect Funds 

The OIG has a responsibility to provide oversight and enforcement activities to protect HHS funds from fraud, waste, and abuse.

These objectives are:

  1. Objective A: Prevent, detect and remedy waste or misspending of COVID-19 response and recovery funds.
  2. Objective B: Fight fraud and abuse that diverts COVID-19 funding from intended purposes or exploits emergency flexibilities granted to health and human services providers. In other words, conduct audits and evaluations.

Goal 3:Protect Infrastructure 

The OIG conducts cybersecurity audits of HHS’ information technology (IT) and provides recommendations to improve protections while deterring cyberattacks.

The objective of this goal is:

  1. Objective A: Protect the security and integrity of IT systems and health technology. One area of focus is auditing cybersecurity vulnerabilities related to networked medical devices, telehealth platforms and other technologies implemented during COVID-19.

Goal 4:Promote Effectiveness

Through auditing and oversight, the OIG provides ongoing recommendations to HHS based on “lessons learned” to support future emergency response effectively.

These objectives are:

  1. Objective A: Support the effectiveness of Federal, State and local COVID-19 response and recovery efforts.
  2. Objective B: Leverage successful practices and lessons learned to strengthen HHS programs for the future. The OIG will be assisting HHS in assessing the impact telehealth expansions had on programs and beneficiaries to impact future responses.

Key Takeaways

Based on this strategic plan, the following will help to determine if your facility is prepared for the response and recovery of COVID-19.

  • Develop financial internal controls, ledgers, and approval processes to ensure dollars received in response to the Provider Relief Fund are tracked and easily accessible and defendable for future audits.
  • Ensure eligibility, use report and other requirements of receiving funds where appropriate. Verify the accuracy of attestations and calculations of funds received.
  • Work with your IT provider to test cybersecurity vulnerabilities related to networked medical devices, telehealth platforms and other technologies being used in COVID-19 response.
  • Ensure any treatment expansions—such as telehealth services—are implemented, coded, billed and documented correctly by adding telehealth auditing to your internal audit plan. Telehealth auditing adds increased complexities to an internal audit plan as many expansions have expiration dates, new service provider exceptions, new guidance on coding and billing, and HIPAA BAA temporary allowances to provide telehealth services. Also, keep in mind telehealth auditing for suspected fraud may require an IT forensic investigation to determine the IP address during the time of service.

 

For more information, contact Deborah Alexander at 717-213-3122 or email DAlexander@LW-Consult.com.

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