Over the past several months, oversight of the COVID-19 Uninsured Program (UIP) by both the Health Resources and Services Administration (HRSA) and the HHS Office of Inspector General (OIG) has ramped up, according to Feldesman Leifer LLP (formerly Feldesman Tucker Leifer Fidell – FTLF). This increase in activity may be due to an OIG report issued in July of 2023 that stated, “[o]n the basis of our sample results, we estimated that nearly $784 million of $4.2 billion (or 19%) of UIP payments made to providers during our audit period for approximately 3.7 million of 19.2 million patients were improper.” In its response to the OIG audit report, HRSA states, among other things, that it will seek to recover improper payments to providers. In addition to the ongoing audits by the HHS OIG, the Division of Program Integrity of HRSA’s Provider Relief Bureau has recently begun random assessments of providers that received UIP funds using its team of contract audit firms. Central to the July OIG report are the terms and conditions that providers agreed to in order to bill the UIP fund for COVID testing and vaccine administration. In addition, the OIG has recently started audits of other providers including Health Centers focused on another, and rather unusual, provision of the terms and conditions. Health centers are urged to review the UIP terms and conditions, protocols for determining uninsured status as well as determine the amount of UIP payments received and how those funds were used and consider strategies to document, among other things, how your organization determined uninsured status and how it can document use of UIP funds. Read more.
