Recommendations Tracker

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.

CMS should conduct additional outreach to beneficiaries to increase awareness about Medicare coverage for the treatment of opioid use disorder.

CMS should assist SAMHSA by providing data about the number of Medicare beneficiaries receiving buprenorphine in office-based settings and the geographic areas where Medicare beneficiaries remain underserved.

CMS should create an action plan and take steps to address disparities in the treatment of opioid use disorder.

We recommend that the Substance Abuse and Mental Health Services Administration update its policies and procedures to require verification that accreditation bodies maintain records that contain sufficient detail to support each accreditation decision.

We recommend that the Colorado Department of Health Care Policy and Financing work with the Colorado Department of Human Services to strengthen its biennial audits of OTPs to ensure that services provided are in accordance with Federal and State requirements.

We recommend that the Colorado Department of Health Care Policy and Financing work with the Colorado Department of Human Services to educate OTPs on the deficiencies we identified in this report to increase their awareness of compliance issues regarding Federal and State requirements.

We recommend that the Oklahoma Health Care Authority consider whether more of an emphasis on counseling could improve OUD outcomes and, if so, take steps to increase the appropriate use of counseling with OUD drugs in outpatient OUD treatment.

We recommend that the California Department of Health Care Services refund $2,416,900 to the Federal Government for unallowable OTP services furnished by the selected provider.

We recommend that the California Department of Health Care Services verify that the selected provider implements corrective action plans that were approved by the State agency.

We recommend that the California Department of Health Care Services work with the selected provider to improve the quality of care provided to beneficiaries by correcting deficiencies.

We recommend that the Choctaw Nation of Oklahoma refund unallowable costs of $2,405 to the TOR grant.

We recommend that the Choctaw Nation of Oklahoma strengthen policies and procedures by clarifying responsibilities between and within Tribal departments for the review and approval of costs submitted on contractor invoices.

IHS should assess the costs and benefits of updating its EHR system with tools to support more automated monitoring.

FDA should use the new TIRF Risk Evaluation and Mitigation Strategy (REMS) patient registry to monitor for known areas of risk, such as inappropriate conversions and off-label prescribing.

FDA should enhance its Risk Evaluation and Mitigation Strategy (REMS) assessment review process.

We recommend that the Ohio Department of Job and Family Services improve monitoring to ensure that the county agencies maintain the required documentation in the Ohio SACWIS14 for the medications prescribed for children in its custody.

We recommend that the Ohio Department of Job and Family Services implement procedures for the monitoring of opioid medications prescribed for children in its custody.

We recommend that the Ohio Department of Job and Family Services provide training and technical assistance to county agency workers who input medical and medication information into the Ohio SACWIS.

CMS should educate Part D beneficiaries about access to MAT drugs and naloxone.

SAMHSA should work closely with States and territories during the no-cost extension period to address barriers to timely spending and to ensure that administrative cost caps are not exceeded.

We recommend that SAMHSA identify steps it can take and take action to ensure that it meets its goal for the number of OTPs it inspects each year.

We recommend that SAMHSA ensure that its compliance officers follow the Compliance Audit Guidance by reviewing alternative patients' charts when parts of a chart are unavailable to determine an OTP's compliance with the Federal opioid treatment standards.

We recommend that SAMHSA comply with Federal regulations and the HHS policy for documenting and retaining its evaluations of accreditation elements.

We recommend that the New York State Department of Health refund $39,329,059 to the Federal Government.

We recommend that the New York State Department of Health implement procedures to detect and prevent duplicate claims for OTP services.

SAMHSA should geographically target its efforts to increase the participation of waivered providers in high-need counties.

CMS should work to ensure that individual beneficiaries can be uniquely identified at a national level using T-MSIS.

CMS should clarify requirements for diagnosis codes.

We recommend that IHS revise the IHM to include the type of action a provider should take and what documentation to include in the patient's EHR when a UDS is unfavorable.

We recommend that IHS increase oversight of IT systems by IHS management, including consideration of centralizing its key IT systems (including RPMS), services, and cybersecurity functions (e.g., patch management, unsupported network equipment and contingency planning) by conducting a cost-benefit analysis and risk assessment of adopting the Cloud First Policy and other means of centralization (e.g., headquarters, area offices). Specifically, determine if a cloud solutions or other modernization approaches are most effective and cost efficient in addressing persistent cybersecurity vulnerabilities and increasing network resiliency.

We recommend that IHS implement a strategic and phased approach to centralization of IT systems, services and cybersecurity functions.

We recommend that IHS work with hospitals to develop policies and procedures to review the EHRs of patients with opioid prescriptions from non-IHS providers and document the results of the review in the EHR, particularly for those patients who had previously violated their COT agreements.

We recommend that IHS work with hospitals to ensure all opioids are in a locked cabinet, safe, drawer, or other appropriate secure container at all times.

We recommend that IHS work with hospitals to analyze opioid data to make decisions and oversee providers to minimize prescribing practices that exceed daily MME guidelines established by IHS, co-prescribe opioids and benzodiazepines, and use opioids for acute pain.

We recommend that IHS work with area offices to renegotiate the MOU with Oklahoma and other States that have restrictive MOU language to allow for PDMP self-audits and collection by clinical directors.

We recommend that IHS should assign a centralized team (e.g., headquarters, area office) to: Ensure patches are deployed timely to all IHS end points in accordance with NIST guidance and IHS policies and procedures.

We recommend that IHS should assign a centralized team (e.g., headquarters, area office) to: Securely configure and monitor wireless access points at all IHS hospitals.

We recommend that IHS should ensure that all devices on IHS's network are scanned for vulnerabilities, scan reports reviewed by appropriate computer personnel, track vulnerability remediation, and ensure that vulnerabilities are remediated in a timely way.

We recommend that IHS should ensure that all hospitals: Store backup tapes off-site in accordance with Federal guidelines.

We recommend that the Penobscot Nation ensure that PNHD is under the medical direction of a physician who performs all of the duties required in the job description and in accordance with Federal and Tribal requirements.

We recommend that the Penobscot Nation conduct annual program evaluations in accordance with Federal requirements, review the results of the program evaluations, and take corrective actions as appropriate.

We recommend that the Penobscot Nation establish a preventative maintenance program for the facility and medical equipment to ensure that it provides a safe, clean, and accessible environment.

We recommend that the Passamaquoddy Tribe at Pleasant Point ensures PPHC is under the medical direction of a physician, in accordance with Federal and Tribal requirements.

We recommend that the Passamaquoddy Tribe at Pleasant Point develop, approve, and implement with the advice of the required group of professional medical staff written medical policies and procedures that include pain-management treatment prioritization requirements for opioid prescription and compliance monitoring and requirements for timely completion, signature, and review of patient health records.

We recommend that the Passamaquoddy Tribe at Pleasant Point implement Federal and Tribal preemployment screening controls for employees who have not been fully screened prior to employment and for new staff hired at PPHC, including the performance of fingerprinting and FBI background checks for all staff currently working with Indian children.

We recommend that IHS assign specific PINs for each employee at Blackfeet Hospital for restricted areas.

We recommend that IHS test all backup mechanisms at Burdick Memorial to ensure patient information is fully recoverable and implement an effective continuity of operations program and disaster recovery plan and procedures in accordance with Federal requirements.

We recommend that IHS perform adequate information security risk assessments at all IHS hospitals in accordance with NIST 800-30.

We recommend that IHS determine if local IHS hospital system administrators are adequately trained to ensure compliance with all flaw remediation and vulnerability management procedures and, if not, develop and implement a training program.