On March 24, 2020, the U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) began reaching out to many hospital administrators to inquire about how they are responding to the COVID-19 national emergency as part of OIG’s planned projects (“Work Plan”). OIG has suggested that these requests are part of its efforts to understand hospitals’ needs, challenges, concerns and strategies under the current public health emergency and that they do not relate to any targeted investigations or audits.
We understand that many hospital administrators across the country are receiving direct requests from OIG, through email and other correspondence, to participate in these interviews. For those responding to these requests, OIG has encouraged relevant hospital personnel such as those in charge of critical incident response, emergency preparedness, infection control or general hospital operations to participate during the interview. According to OIG, hospital administrators should expect the interviews to take no more than 20 minutes, and they should also anticipate receiving in advance a written description of the interview topics, which may consist of the following:
- An approximation of the numbers of COVID-19 patients seen by the hospital;
- Challenges faced by the hospital in responding to COVID-19;
- Strategies employed by the hospital to address or mitigate those challenges; and
- Ways that the federal government can best support hospitals responding to COVID-19.
According to the Work Plan, OIG will aggregate interview responses from a sample of approximately 400 hospitals nationwide that include a range of hospital types, sizes and locations, including rural and critical access hospitals. OIG claims that this study is meant to help OIG understand what health care providers are facing as those closest to ground zero in this challenging era of COVID-19, including ensuring the availability of personal protective equipment for hospital staff. OIG has suggested that it intends to use the results from this study to issue, in the very near future, a public report and provide HHS and Congress with feedback on how to support hospitals in responding to COVID-19. Recognizing that this is a critical time for many hospitals, OIG has shown some flexibility in scheduling interviews with participating hospitals.
We hope that OIG’s findings through this effort can further support hospitals and health care providers with important, accurate anecdotal information during these challenging times. Please be advised, however, that we do not know where these interviews could lead if OIG learns of potential gaps or other issues at specific hospitals and health systems.
If you have any questions or would like additional information about this topic, please contact:
- Scott Taebel at 414-721-0445 or staebel@hallrender.com;
- Katherine Kuchan at 414-721-0479 or kkuchan@hallrender.com;
- Kristen Chang at 414-721-0923 or kchang@hallrender.com; or
- Your regular Hall Render attorney.