Assisted living hospice care, Medicaid personal care services, home- and community-based services waiver programs and Medicaid data are four topics that made the top 25 list included in the Health and Human Services Office of Inspector General’s “2017 Compendium of Unimplemented Recommendations.”
Assisted living hospice care. Coming in at No. 5 was the recommendation that the Centers for Medicare & Medicaid Services reform hospice payments to reduce the incentive for hospices to target beneficiaries with certain diagnoses and those likely to have long stays.
“For example,” the report authors wrote, “hospices provided care over longer periods and received much higher Medicare payments for beneficiaries in assisted living facilities than for beneficiaries in other settings.”
The OIG also included this recommendation in its 2016 report and noted that CMS believes that its new payment structure addresses it. “OIG does not consider the new payment structure to be the best way to align payments with patient needs because it does not address the vulnerability of hospices targeting beneficiaries to achieve the greatest financial gains,” however, the report stated.
Medicaid personal care services. No. 12 on the list of top 25 unimplemented recommendations was the one calling on CMS and the states to strengthen the program integrity of Medicaid personal care services by requiring states to either enroll all personal care services attendants as providers or by requiring all personal care services attendants to register with their state Medicaid agencies and assigning each attendant a unique identifier.
“For the past eight years, OIG has identified program integrity for Medicaid home- and community-based services (HCBS), particularly PCS, as a top management concern for the department,” the report authors noted.
CMS, according to the OIG, believes that regulatory change is necessary to implement the OIG’s recommendations and is analyzing comments it received from a request for information to determine possible policy changes. The outstanding OIG recommendations may be able to be resolved, depending on the actions CMS takes, the OIG said.
HCBS waiver programs. No. 13 on the list was the recommendation that CMS ensure that state Medicaid agencies do not claim unallowable room-and-board and certain other unallowable and unsupported costs related to providing services under HCBS waiver programs.
To aid in this process, the OIG recommended that CMS share the findings of the OIG’s HCBS waiver program audits with all state agencies, share at CMS’ discretion the other findings of the OIG’s HCBS waiver program audits with all state agencies, and encourage all state agencies to review their procedures for calculating and claiming costs under their HCBS waiver programs.
“CMS concurred with our recommendations and indicated that it continues to provide guidance to states on their procedures for calculating and claiming costs under HCBS waiver programs,” the report noted.
Medicaid data. No. 15 on the list was the recommendation that CMS ensure that Medicaid data are complete, accurate and timely.
The OIG said that CMS can achieve this recommendation by monitoring state-submitted managed care encounter data and by implementing the national Transformed Medicaid Statistical Information System.
“CMS concurred with our recommendations and indicated that all states are working toward T-MSIS implementation with the goal of every state submitting data in 2017,” the report noted. “CMS stated that it is working with states to ensure that encounter data include data from all contracted managed care entities and has correct plan identifiers.”