The Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) has released the 2017 edition of its Compendium of Unimplemented Recommendations (“Compendium”). In the Compendium, OIG identifies the top 25 unimplemented recommendations that HHS would need to prioritize in order to facilitate OIG’s recommendations on cost savings, program effectiveness, efficiency, and quality improvements in HHS programs. More than half of these top 25 recommendations focus on programs regulated by the Centers for Medicare & Medicaid Services (CMS), while others focus on programs regulated by other HHS agencies and states. The top priorities identified by the OIG in the Compendium include recommendations broadly aimed at:
- Protecting beneficiaries from drug abuse, including opioid abuse
- Ensuring program integrity, quality of care, and safety in programs that serve children
- Reducing Medicaid fraud and patient harm, including in the delivery of personal care services
- Reducing home health fraud
- Promoting economy and efficiency in drug pricing and reimbursement
To facilitate cost savings in Medicare Parts A and B, OIG recommends that CMS: adjust reimbursement rates for critical access hospital swing-beds to match the lower rates paid for similar services in skilled nursing facilities; adjust payment for hospital outpatient procedures to match lower rates for similar procedures in ambulatory surgical centers; reduce hospital reimbursement for beneficiaries discharged early to hospice care; and adjust Medicare payments for therapy services in skilled nursing facilities. Further, stating its concern with widespread occurrences of adverse events causing harm to Medicare beneficiaries, OIG recommends that CMS and the Agency for Healthcare Research and Quality identify and address adverse events in rehabilitation hospitals and nursing homes.
For Medicare Part C and D, OIG recommends that CMS implement policies and procedures to notify Medicare Advantage organizations of payments made to individuals who are not U.S. citizens or nationals. Further, in light of increased spending on prescription drugs, as well as increases in opioid abuse, OIG recommends that CMS implement its new Medicare Part D beneficiary “lock in” authority under the Comprehensive Addiction and Recovery Act of 2016. The “lock in,” when implemented, would restrict beneficiaries to a limited number of pharmacies or prescribers when warranted, especially in situations where beneficiaries are “doctor shopping” or seeking unnecessary prescriptions. The policy also is intended to aid beneficiaries being harmed by overprescribing.
With regard to Food and Drug Administration (FDA) programs, OIG expresses concern with the number of deaths and sicknesses resulting from contaminated foods and beverages. It first recommends that FDA ensure that all food facilities with significant violations during FDA inspections correct all such violations. Further, it states that FDA should consider seeking statutory authority to impose civil penalties against facilities that fail to comply with statutory and regulatory requirements.
The complete list of significant unimplemented recommendations can be found in the Compendium’s Appendix.