The Department of Health and Human Services Office of Inspector General has issued its annual summary of the most significant management and performance challenges facing HHS and not surprisingly information technology figures prominently in the OIGs fiscal year 2014 list.
These challenges reflect continuing vulnerabilities that OIG has identified for HHS over recent years as well as new and emerging issues that HHS will face in the coming year, according to auditors, who compiled a list of the top 10 challenges confronting the department.
Number one on the OIGs list is implementing, operating and overseeing health insurance marketplaces, which auditors conclude was among the most significant challenges for HHS in fiscal year 2014 and will continue to present a top management and performance challenge in FY 2015.
In 2015, CMS and the Health Insurance Marketplaces face new and ongoing challenges including, for example, ensuring accurate eligibility determinations; processing enrollments, re-enrollments, and qualifying life change events; and communicating timely and accurate information to health insurance issuers and consumers, argues OIG. Marketplaces must also facilitate Medicaid enrollment for those who qualify. In coordination with states, CMS will implement premium-stabilization programs. To carry out these complex Marketplace functions, the Department must ensure effective communication and coordination between and among all internal and external parties with Marketplace responsibilities, including within HHS and with contractors, issuers, and partners in state and federal government.
OIG also asserts that the effective coordination with, and timely provision of accurate data to, the Internal Revenue Service will be particularly important for sound administration of the premium tax credit program. In addition, auditors make the case that CMS will need to be attentive to state Marketplace operations to ensure state compliance with requirements, including transmitting accurate and timely data used for federal payments.
Number six on OIGs top 10 list of challenges is the meaningful and secure exchange and use of electronic health information. Auditors note that as of September 2014 the Medicare and Medicaid EHR Incentive Programs have paid out $25.4 billion in incentive payments. Nonetheless, while program interest has been high among eligible hospitals and professionals, OIG reveals that recent data suggest that not all those currently participating will continue to do so.
If the number of program participants were to decrease, fewer eligible professionals, eligible hospitals, and [critical access hospitals] would progress to Stage 2 meaningful use, which includes a focus on health information exchange, according to OIG. And, although participation in the Medicare and Medicaid EHR Incentive Programs is high and has led to widespread adoption among eligible providers, auditors point out that significant challenges exist with respect to overseeing the EHR Incentive Programs, achieving interoperability of EHRs, and keeping sensitive health information secure.
Moreover, they argue that as HHS works to link payments with care quality, health outcomes, or performance as part of health care delivery system reforms, it will need to ensure that EHR and other health information data are accurate and reliable and are protected from misuse.
According to OIG, it has uncovered vulnerabilities in oversight controls for EHR incentive payments as well as the accuracy of EHR incentive payment calculations. Auditors also say they found that CMS and states did not implement strong prepayment controls and relied primarily on post-payment audits of high-risk participants to confirm that payments were appropriate. In addition, OIG found that CMS and states lacked adequate data to verify participants self-reported attestations about their eligibility and meaningful use of EHRs.
ONC requires EHRs to generate audit reports for some, but not all, meaningful use measures; this requirement may create some oversight obstacles for CMS to verify payment during post-payment audits, OIG observes.
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