July 10, 2017
By Paul Westfall*
The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently released an update to its Work Plan. The Work Plan summarizes new and ongoing reviews and activities that the OIG plans to pursue with respect to HHS programs and operations during the current fiscal year and beyond. Instead of releasing the Work Plan once or twice a year, OIG now is updating its Work Plan on a monthly basis. This first monthly update includes 16 total topics with two specifically addressing health care reform.
Medicare Shared Savings Program (MSSP): ACOs must meet minimum levels of specified quality measures to be eligible to receive shared savings. In addition to ongoing work examining Accountable Care Organizations (ACOs) under the MSSP, including beneficiary assignment, OIG will now examine the data ACOs submit regarding these quality measures. OIG also may look at whether the data submitted to the Centers for Medicare and Medicaid Services (CMS) is complete and accurate.
Quality Payment Program (QPP): In December 2016, OIG reported in an early implementation review that CMS staff decided providers’ acceptance of the QPP, and readiness to participate in it, was the critical factor to ensure QPP’s success. Furthermore, the early implementation review indicated that while CMS had made significant progress towards implementing the QPP, providing guidance and developing IT systems were vulnerabilities that could impact QPP’s implementation. In the continued assessment of the QPP implementation, OIG will review CMS’ provider outreach and training efforts and determine the status of IT system development, including security and functionality testing.
*We would like to thank Paul Westfall (American Medical Association, Washington, DC) and Theresa E. Thompson (Epstein Becker & Green PC, Washington, DC) for respectively authoring and reviewing this Alert.