Archive

Archive for the ‘Office of Inspector General’ Category

HHS OIG — Medicare’s Oversight of Compounded Pharmaceuticals Used in Hospitals

January 28, 2015 Comments off

Medicare’s Oversight of Compounded Pharmaceuticals Used in Hospitals
Source: U.S. Department of Health and Human Services, Office of Inspector General

WHY WE DID THIS STUDY
A 2012 nationwide meningitis outbreak caused by contaminated injections, which were produced by a standalone compounding pharmacy, raised concerns about compounded sterile preparations (CSPs). Subsequent OIG work found that almost all acute-care hospitals use CSPs and most contract with standalone compounding pharmacies to provide at least some of these products. CMS oversees the safety of CSPs prepared and used in Medicare-participating hospitals through the hospital certification process, in which State survey agencies or CMS-approved accreditors assess hospital compliance with requirements for drug compounding. This study provides information about the extent to which Medicare’s oversight of hospitals addresses recommended practices for CSPs. In 2013, Congress passed the Drug Quality and Security Act, which clarifies the Food and Drug Administration’s authority over standalone compounding pharmacies.

HOW WE DID THIS STUDY
We reviewed the practices of the five entities that oversee hospitals that participate in Medicare-namely, CMS and the four hospital accreditors approved by CMS. Through consultation with experts in CSP oversight, OIG identified 55 recommended practices for CSP oversight in acute-care hospitals. Representatives from each oversight entity participated in a structured interview and completed a questionnaire about how their respective surveys of hospitals incorporate these recommended practices. We analyzed the data from the interviews and the questionnaire to determine the extent to which Medicare’s oversight addresses recommended practices for CSP oversight.

WHAT WE FOUND
Oversight entities address most of the recommended CSP-related practices at least some of the time. However, only one oversight entity always reviews hospital contracts with standalone compounding pharmacies. Oversight entities may also lack the human capital required to thoroughly review hospitals’ preparation and use of CSPs. Surveyors receive limited training specific to compounding, and most oversight entities do not routinely include pharmacists on hospital surveys. Finally, although most oversight entities are considering changes to how they oversee hospitals’ preparation and use of CSPs, none of them are considering changes to how they oversee hospitals’ contracts with standalone compounding pharmacies.

WHAT WE RECOMMEND
CMS should (1) ensure that hospital surveyors receive training on standards from nationally recognized organizations related to safe compounding practices and (2) amend its interpretive guidelines to address hospitals’ contracts with standalone compounding pharmacies. CMS concurred with both recommendations.

USPS OIG — The “First and Last Mile” Strategy: A Critical Assessment

January 23, 2015 Comments off

The “First and Last Mile” Strategy: A Critical Assessment (PDF)
Source: U.S. Postal Service, Office of Inspector General
From Summary:

As the Postal Service continues to address its difficult financial situation, some have argued that overall efficiency would improve if the Postal Service were to focus exclusively on the first and last mile (collection and delivery). While the introduction of workshare discounts has led to private industry taking over a portion of the middle mile – mail processing and transportation – allowing private industry to take over the entire middle mile warrants close examination. We therefore asked Dr. John Panzar, an expert in postal economics, to look at the economic implications of the Postal Service abandoning the middle mile completely and focusing exclusively on the first and last mile for the letter and flat market.

Dr. Panzar finds that the Postal Service’s mail processing plays a vital role in ensuring the efficiency of the postal sector, even in the absence of economies of scale in mail processing. In other words, Dr. Panzar maintains that if the Postal Service abandons all mail processing and transportation of letters and flats, overall efficiency will decrease. Worse, the Postal Service would experience a loss in profits, and mailers would have to pay higher prices. In fact, the only parties benefiting would be the private providers of mail processing, but their benefit would be less than the combined loss to the Postal Service and mailers.

The parcel market, which is different and requires its own focused attention and stylized model, will be addressed in a future white paper.

HHS OIG — Federal Marketplace: Inadequacies in Contract Planning and Procurement

January 21, 2015 Comments off

Federal Marketplace: Inadequacies in Contract Planning and Procurement
Source: U.S. Department of Health and Human Services, Office of Inspector General

WHY WE DID THIS STUDY
The Federal Marketplace at HealthCare.gov was designed to enable millions of Americans to select health insurance in a “one-stop shop” environment. A project of this magnitude and complexity required the development, integration, and operation of multiple information technology (IT) systems and Government databases. CMS acquisition planning and procurement activities were among the first steps critical to ensuring the success of this project. CMS awarded 60 contracts across 33 companies to perform this work. The troubled launch of the Federal Marketplace at HealthCare.gov in October 2013 raised a number of concerns, including questions about the adequacy of CMS’s planning and procurement efforts for this key project under the Affordable Care Act.

HOW WE DID THIS STUDY
We conducted a detailed review of documentation provided by CMS for the 60 Federal Marketplace contracts, selected 6 key contracts for indepth review, and interviewed Department of Health and Human Services (HHS) and CMS officials involved with contracting for the Federal Marketplace. We also reviewed procurement regulations, manuals, guides, and procedures provided by both HHS and CMS for acquisition planning, contractor selection, and contracting oversight processes.

WHAT WE FOUND
When awarding the Federal Marketplace contracts, CMS did not always meet contracting requirements. For example, CMS did not develop an overarching acquisition strategy for the Federal Marketplace or perform all required oversight activities. Moreover, for a project of this size and importance, CMS missed opportunities to leverage all available acquisition planning tools and contracting approaches to identify and mitigate risks. Specifically, CMS did not exercise the option to plan for a lead systems integrator to coordinate all contractors’ efforts prior to the launch of the Federal Marketplace. The complexity of the Federal Marketplace underscored the need for CMS to select the most qualified contractors. However, CMS did not perform thorough reviews of contractor past performance when awarding two key contracts. CMS also made contracting decisions that may have limited the number of acceptable proposals for much of the key Federal Marketplace work. In addition, CMS selected contract types that placed the risk of cost increases for this work solely on the Government.

WHAT WE RECOMMEND
We recommend that (1) CMS ensure that acquisition strategies are completed as required by regulation, (2) CMS assess whether to assign a lead systems integrator for complex IT projects, (3) CMS ensure that contract actions are properly documented, (4) CMS ensure that all contracts subject to oversight review requirements undergo those reviews, (5) HHS limit or eliminate regulatory exceptions to acquisition planning requirements, and (6) HHS revise its acquisition guidance to include specific standards for conducting past performance reviews. HHS and CMS concur with all of our recommendations.

Medicare Hospices Have Financial Incentives To Provide Care in Assisted Living Facilities

January 16, 2015 Comments off

Medicare Hospices Have Financial Incentives To Provide Care in Assisted Living Facilities
Source: U.S. Department of Health and Human Services, Office of Inspector General

WHY WE DID THIS STUDY
Medicare hospice care is intended to help terminally ill beneficiaries continue life with minimal disruption and to support beneficiaries’ families and other caregivers in the process. Care may be provided in various settings, including a private home or other places of residence, such as an assisted living facility (ALF). Pursuant to the Patient Protection and Affordable Care Act, CMS must reform the hospice payment system, collect data relevant to revising hospice payments, and develop quality measures for hospices. This report provides information to inform those decisions and is part of OIG’s larger body of work on hospice care. While the report focuses on ALFs, many of the issues identified pertain to the hospice benefit more broadly.

HOW WE DID THIS STUDY
We based this study on an analysis of all Medicare hospice claims from 2007 through 2012. We used Certification and Survey Provider Enhanced Reports data and Healthcare Cost Report Information System reports for supplementary information on hospice characteristics.

WHAT WE FOUND
Medicare payments for hospice care in ALFs more than doubled in 5 years, totaling $2.1 billion in 2012. Hospices provided care much longer and received much higher Medicare payments for beneficiaries in ALFs than for beneficiaries in other settings. Hospice beneficiaries in ALFs often had diagnoses that usually require less complex care. Hospices typically provided fewer than 5 hours of visits and were paid about $1,100 per week for each beneficiary receiving routine home care in ALFs. Also, for-profit hospices received much higher Medicare payments per beneficiary than nonprofit hospices. This report raises concerns about the financial incentives created by the current payment system and the potential for hospices to target beneficiaries in ALFs because they may offer the hospices the greatest financial gain. Together, the findings in this and previous OIG reports show that payment reform and more accountability are needed to reduce incentives for hospices to focus solely on certain types of diagnoses or settings.

WHAT WE RECOMMEND
We recommend that CMS, as part of its ongoing hospice reform efforts: (1) reform payments to reduce the incentive for hospices to target beneficiaries with certain diagnoses and those likely to have long stays, (2) target certain hospices for review, (3) develop and adopt claims-based measures of quality, (4) make hospice data publicly available for beneficiaries, and (5) provide additional information to hospices to educate them about how they compare to their peers. CMS concurred with all five recommendations.

Flexibility at Work: Human Resource Strategies to Help the Postal Service

January 15, 2015 Comments off

Flexibility at Work: Human Resource Strategies to Help the Postal Service (PDF)
Source: U.S. Postal Service, Office of Inspector General

Highlights

  • The Postal Service has a strategic need to attract adaptable, committed workers to compete in the future.
  • The OIG conducted primary and secondary research to discover innovative human resources practices in successful organizations.
  • Policies that improve work-life balance can attract committed employees and improve retention. Positive outcomes include a less stressed workforce, better customer service, and increased productivity.
  • The Postal Service is focused on workforce flexibility, using lower paid employees to supplement its career workforce. It should also focus on workplace flexibility policies that improve work-life balance.
  • A strategic partnership between management and the workforce throughout the organization will be needed to move toward a more flexible work culture.
  • Experimentation, feedback from employees, and better workload information and management tools all increase the likelihood that flexibility policies will succeed.

USPS OIG — Parcel Payment Technologies and Payment Strategies

January 12, 2015 Comments off

Parcel Payment Technologies and Payment Strategies (PDF)
Source: U.S. Postal Service, Office of Inspector General

A new white paper from the Office of Inspector General proposes the U.S. Postal Service must consider additional payment options that address how individuals and small business conduct transactions. Providing flexible payment options will allow the Postal Service to capitalize on revenue in shipping and package services and be more relevant in the digital age. The findings and recommendations found in this report are in line with the numerous advancements in technology, e-commerce, and mobile technology and there connections with the future of the business world.

VA OIG — Review of Alleged Mismanagement of VA’s Office of Public and Intergovernmental Affairs Outreach Contracts

January 7, 2015 Comments off

Review of Alleged Mismanagement of VA’s Office of Public and Intergovernmental Affairs Outreach Contracts (PDF)
Source: U.S. Department of Veterans Affairs, Office of Inspector General

We evaluated the merits of Hotline complaints that VA’s Office of Public and Intergovernmental Affairs (OPIA) awarded an outreach contract to Woodpile Studios, Inc., alleging that it yielded no apparent increase in the use of VA healthcare, benefits, or services by veterans and then planned to solicit new outreach contracts without evaluating the effectiveness of the prior contract.

We substantiated the allegations regarding OPIA mismanagement of its outreach contracts. We confirmed that in July 2010, OPIA awarded a contract to Woodpile Studios, Inc. to provide support for outreach campaigns at an initial cost of $5.2 million. However, OPIA could not demonstrate that contract activities resulted in increased awareness of and access to VA healthcare, benefits, and services for veterans.

We also confirmed that OPIA solicited significant new outreach service contracts without evaluating the effectiveness of the previous contract. OPIA management stated that leadership turnover contributed to ineffective oversight of the outreach contract management and solicitations. Consequently, Woodpile contractors performed functions that were inherently Governmental. Questionable use of a labor-hour order instead of a performance-based contract contributed to invoices for activities that did not clearly link to accomplishment of VA outreach goals.

By awarding new contracts without first evaluating the performance of the prior Woodpile contract, OPIA continued to expend funds on questionable outreach activities. OPIA also lacked performance metrics to fully assess improvements in access to VA benefits and services for veterans.

We recommended that the Assistant Secretary for the Office of Public and Intergovernmental Affairs ensure effective oversight of outreach contract management and prevent contractors from performing inherently Governmental tasks. The Assistant Secretary should also implement metrics to ensure the outreach campaigns improve veteran awareness and access to VA services.

The Acting Assistant Secretary for the Office of Public and Intergovernmental Affairs concurred with our report recommendations and summarized corrective actions for our consideration. We will monitor implementation of the corrective action plans.

See also: Audit of VHA’s Support Service Contracts (PDF)

Follow

Get every new post delivered to your Inbox.

Join 1,000 other followers