Recommendations Tracker

We recommend that the Centers for Medicare & Medicaid Services take the following actions to align its bundled payment rates with OUD treatment services provided to enrollees during an episode of care, which could have saved Medicare an estimated $301,479,659 during our audit period, use the results of our audit or gather additional information on the combination of OUD treatment services and the frequency of each type of treatment service provided to Medicare enrollees, and consider revising its methodology for determining the nondrug component of the weekly bundled payment rates.

We recommend that the Centers for Medicare & Medicaid Services work with SAMHSA (or a designated agency) to perform monitoring activities to ensure OTPs have properly documented OUD treatment services in enrollees' treatment plans.

We recommend that the Florida Department of Children and Families (DCF) update the reconciliation process, or consider an alternative approach, so that Federal Financial Reports (FFRs) are submitted accurately and refunds of unspent funds are executed timely.

We recommend that the Florida Department of Children and Families (DCF) require that Managing Entities (MEs) strengthen controls over service data entry and support maintained by network service providers.

We recommend that the Florida Department of Children and Families (DCF) develop policies and procedures for maintaining data used to prepare progress reports for State Opioid Response (SOR) grants, including a standardized process for using data when reporting program goal outcomes.

CMS should educate Medicare providers about Medicare services that help enrollees continue treatment for opioid use disorder.

CMS should assess and make changes, as appropriate, to the bundled payment codes for office-based treatment to ensure they meet provider and enrollee needs.

CMS should geographically target efforts to increase the number of MOUD providers that treat Medicare enrollees in high-need counties.

CMS should work with SAMHSA to develop and maintain a list of active office-based buprenorphine providers.

We recommend the Massachusetts Executive Office of Health & Human Services follow up with the OTP providers to correct the three services that were not supported by the medical records.

We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs complete required tests for enrollee admissions and adequately document enrollee admissions.

We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs provide take-home medications in accordance with Federal and State requirements.

We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs adequately document the results of drug screens.

We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs adequately document enrollee assessments.

We recommend that the Washington State Health Care Authority work with its contracted MCOs and the Department of Health to ensure that OTPs comply with Federal and State requirements for providing and documenting OTP services, including ensuring that OTPs complete and adequately document annual medical examinations.

We recommend that West Virginia's Bureau of Behavioral Health include requirements in its procedures to maintain documentation used to prepare the annual progress report.

We recommend that West Virginia's Bureau of Behavioral Health revise pre-designed progress reports to capture the necessary data to determine whether program goals are being met.

We recommend that West Virginia's Bureau of Behavioral Health revise procedures to ensure that subrecipient agreements are finalized and closed out with returned funds recorded in the general ledger prior to filing the Federal financial report.

We recommend that DMHAS identify factors that could delay grant-funded activities when estimating goals for future STR and SOR grant applications.

We recommend that the California Department of Social Services establish procedures for county agency staff to document all medications (including opioid medications) prescribed for children in foster care in CWS/CMS, to the extent allowable under California law.

We recommend that the California Department of Social Services establish procedures for county agency staff to utilize Medicaid data match reports to verify that court authorizations for psychotropic medications prescribed for children in foster care are documented and maintained.

CMS should educate enrollees and providers about options for access to overdose-reversal medications, as Narcan and its generic equivalents will no longer be covered by Part D.

CMS should encourage and support States' efforts to reduce barriers to medications for opioid use disorder (MOUD), especially among groups who may be underserved.

We recommend that the Centers for Medicare & Medicaid Services work with MACs to determine whether claims billed by OTPs for OUD treatment services complied with Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services instruct MACs to implement edits in their claims processing systems to prevent an OTP from being paid for: (1) a weekly bundle with a service date that was within a contiguous 7-day period of another weekly bundle's service date for the same enrollee at the same OTP or (2) two weekly bundles with the same service date for the same enrollee at the same OTP.

We recommend that the Centers for Medicare & Medicaid Services develop billing requirements for OTPs to include OUD diagnosis codes on claims for OUD treatment services to indicate that enrollees have OUD diagnoses, and consider working with MACs to implement a system edit to ensure that OTP payments are made for enrollees only when OUD diagnosis codes are included on claims.

We recommend that the Florida Department of Children and Families provide training to CPIs and caseworkers on medication management and administration that addresses requirements for updating case records in FSFN for children who are prescribed psychotropic medications (including related medication logs and authorizations) and opioid medications.

We recommend that the Vermont Department of Health, Division of Substance Use Programs refund $282,643 to the Federal Government.

We recommend that the Vermont Department of Health, Division of Substance Use Programs conduct a periodic review of supporting documentation (i.e., invoices, payroll registers, and time and effort reports) for subrecipient expenditures submitted to DSU for reimbursement.

We recommend that the Vermont Department of Health, Division of Substance Use Programs conduct annual site visits as required within the terms and conditions of the grant award that include program and fiscal reviews.

CMS should monitor the use of buprenorphine and share information, as appropriate, with Departmental partners.

CMS should take steps to inform providers about the availability of buprenorphine combination products in Part D, which can minimize the risk of misuse and diversion.

We recommend that the Michigan Department of Health and Human Services ensure that electronic case records for the children under its care and supervision are maintained in accordance with State requirements by modifying procedures for the monitoring of caseworkers to include a review of medical passports in MiSACWIS.

We recommend that the Michigan Department of Health and Human Services ensure the electronic case records for children who are prescribed opioid medications are maintained in accordance with requirements by implementing procedures requiring caseworkers to monitor Medicaid claim data for opioid medications prescribed for the children and providing training to caseworkers on the requirements for documenting medications prescribed for the children in MiSACWIS, including opioid medications due to medical procedures or emergency treatments.

We recommend that the Indiana Department of Child Services ensure that health care records for the children under its care and supervision are maintained in accordance with State requirements by providing training and technical assistance to the FCMs on how to maintain health care records and input medications in MaGIK, implementing additional controls and procedures to ensure medications prescribed for children are input in MaGIK, implementing additional procedures to ensure the required authorizations for psychotropic medications are obtained and documented, and implementing additional procedures to ensure the required 30-day written reports and 90-day medical reviews are obtained and documented for children residing in residential facilities who are prescribed psychotropic medications.

We recommend that the Indiana Department of Child Services continue efforts with the Indiana Family and Social Services Administration to obtain access to Medicaid claim history.

We recommend that the New Hampshire Department of Health and Human Services refund $7,943,271 to the Federal Government.

We recommend that the New Hampshire Department of Health and Human Services improve communication with providers regarding the State requirements for OUD treatment and provide written confirmation to providers about whether offsite counseling may be included as a required counseling service.

We recommend that the California Department of Health Care Services refund $23,139,767 to the Federal Government.

We recommend that the California Department of Health Care Services consider performing additional postservice prepayment monitoring and postservice postpayment utilization reviews.

We recommend that the California Department of Health Care Services revise the Drug Medi-Cal Billing Manual or provide additional guidance to OTPs regarding the allowable number of counseling service units and work with counties to ensure that their OTP billing manuals do not conflict with State regulations.

We recommend that the California Department of Health Care Services take actions to ensure that OTPs provide the number of counseling services specified in a beneficiary's treatment plan or document the reasons that counseling services were not provided as specified in the treatment plan.

We recommend that the California Department of Health Care Services take actions to ensure that OTPs have their physicians review and countersign beneficiaries' treatment plans within the 14-day period as required.

We recommend that Louisiana's Office of Behavioral Health develop a process to ensure accurate reporting on the Annual Progress Reports.

We recommend that Louisiana's Office of Behavioral Health work with the LGEs and OTPs to identify ways to support clients' access to transportation to obtain treatment and determine how transportation could be addressed in each specific region of the State.