On March 23, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) updated its Work Plan in response to the COVID-19 pandemic. The OIG Work Plan sets forth planned or ongoing agency evaluations, audits and inspections.
The March 2020 updates to OIG’s Work Plan related to COVID-19 include the following:
1. COVID-19 Hospital Response. As hospitals face a surge in patients due to the COVID-19 pandemic, OIG recognizes its role in helping hospitals effectively manage this public health emergency. OIG’s Office of Evaluation and Inspections will conduct a study to gain insight from hospital administrators on hospital needs and concerns regarding diagnosing and treating COVID-19 patients and other emergency preparedness and response issues, including the availability of personal protective equipment (PPE) for hospital staff. The study will involve interviews of hospital administrators from approximately 400 hospitals of various types, sizes and locations across the country, including rural and critical access hospitals. HHS operating and staff divisions will use the study results to tailor their support of hospitals facing the COVID-19 pandemic.
2. Medicaid Nursing Home Life Safety and Emergency Preparedness Reviews. In 2016 and 2019, CMS addressed concerns for vulnerable beneficiaries residing in nursing homes through updates to its healthcare facilities’ life safety and emergency preparedness requirements and expanded guidance on responding to emerging infectious diseases. Based on the patient population in long-term care (LTC) facilities, which is especially vulnerable to COVID-19, OIG Office of Audit Services is focusing on LTC facilities’ compliance with new federal requirements for life safety and emergency and infectious disease control preparedness.
3. Assessing HHS Agencies’ Adherence to Health, Safety, and Operational Protocols During Repatriation and Quarantine Efforts for the COVID-19 Pandemic. OIG’s Office of Evaluation and Inspections will review how HHS personnel were deployed, trained and protected on assignments that could involve potential COVID-19 exposure, including tasks at quarantine sites and ports of entry. OIG will examine measures taken to protect HHS staff and the public before, during and after deployment to the assignment, as well as any established methods for identification and correction of vulnerabilities in deployment protocols.
4. Highlights of OIG’s Emergency Preparedness Work: Insights for COVID-19 Response. Due to OIG’s key role in protecting beneficiaries and providing guidance for responding to public health emergencies, OIG’s Office of Evaluations and Inspections will highlight relevant issues from prior OIG evaluations and audits related to emergency preparedness and response to inform HHS’s continuing COVID-19 response. The resulting work product will synthesize the main findings and recommendations from these prior evaluations and audits.
5. Emergency Preparedness and Response at Care Provider Facilities in the Office of Refugee Resettlement’s Unaccompanied Alien Children (UAC) Program. With $5 million appropriated through the Emergency Supplemental Appropriations for Humanitarian Assistance at the Southern Border Act of 2019 (P.L. 116-26), OIG’s Office of Audit Services will conduct an additional review of the UAC Program’s emergency preparedness and response plans and procedures. Required safety plans for all UAC and program staff must address various emergency situations, including disease outbreaks such as COVID-19, and each facility must have policies and procedures to identify, report and control communicable diseases like COVID-19. Every licensed care provider facility must follow state licensing requirements for emergency preparedness and response. OIG’s review is designed to assess compliance of selected care provider facilities with federal and state requirements related to emergency situations.
As OIG enhances oversight related to the COVID-19 response, continued prioritization of compliance efforts is key. Providers and entities in the areas identified in the Work Plan updates, including LTC providers, should ensure they comply with OIG’s guidance on life safety, infectious diseases, and emergency preparedness and response efforts. Hospital administrators should be prepared to describe their needs and concerns related to their COVID-19 response, particularly including any needs or problems related to PPE. OIG’s consolidated guidance on emergency preparedness findings and recommendations, which will leverage prior evaluations and audits in the emergency preparedness space, will be a helpful tool when it becomes available. Providers should continue to monitor the OIG Work Plan and OIG COVID-19 Portal for additional updates.
If you have any questions about the HHS OIG updated Work Plan, please contact the authors of this alert.