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ウィスパリング同時通訳研究会コミュのInspector General Christi A. Grimm HCCA 26th Annual Compliance Institute Keynote Speech

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Good morning to the Health Care Compliance Association (HCCA) community.
And thank you, Gerry, for the kind introduction. It is my pleasure to address the compliance community. In June, I was nominated by President Biden. And in February, the Senate confirmed me as the Inspector General for the Department of Health and Human Services (HHS).
It is my great honor to lead this organization of over 1,600 professionals, including auditors, evaluators, analysts, investigators, and attorneys. All are committed to making HHS programs run better—to better serve beneficiaries and better protect taxpayer dollars. I always enjoy addressing the HCCA community. Our missions so closely align. I appreciate how compliance professionals work to make sure your organizations deliver good patient care and are sound stewards of resources. At the same time, you juggle competing needs from owners, boards of trustees, boards of directors, health care workers, and others.
Being the Inspector General of the largest civilian Department amid a worldwide pandemic and unprecedented levels of health care and public health spending is a responsibility I do not take lightly. HHS spent $2.4 trillion in 2021 or about the same size as the economy of France. The Office of Inspector General (OIG) an compliance professionals know what it is like to take on big responsibilities and use scarce resources wisely.
As an Inspector General, my role is to be impartial and objective. We follow the facts wherever they lead. We provide credible data, information, and recommendations to HHS officials and policymakers. Like every Inspector General, I bring to the role my own core values that will guide how the office operates, our engagement with stakeholders, and our priorities. I want to share a few of those values with you and offer some insights into what you can expect from OIG.

The four values I want to highlight today are people-focused results, pragmatism, preparedness, and transparency.
Especially in times of uncertainty, when there is no precise instruction manual and few easy answers, our core values guide and sustain us.
I credit my grandfather for many of the values that guide me, values that have shaped my career in public service, and values that translate well to the work we are focused on at OIG. Throughout my childhood, my grandfather, Albert Mackenson was the head of the Public Works Department in Edgewater, Colorado. Edgewater spans about a mile in each direction and is close enough to Denver to be able to bike in for work but far enough away to retain a small-town feel.
“Mack,” as my grandfather was known, kept the town of Edgewater running. He was in charge of quite a bit. He ensured that the parking lots at City Hall were striped, so people knew where to park. He helped residents understand city codes for raking leaves and garbage removal. He responded to unplanned incidents such as broken water pipes. His work allowed the town to run effectively and efficiently. And his work ultimately served to improve the lives of the people who lived there. This work made a lasting impression on me and shaped the trajectory of my public service career.
You never really pay much attention to your water or sewer when it’s working, right? You turn on a faucet and water flows out, flush the toilet and the wastedrains away. But when it’s not working, you really notice. Mack understood that when critical needs are not met, it creates a significant disruption. His was not always glamorous work, but he did not allocate his time and effort based on what was most glamorous or fun. Instead, he placed value on what was most critical, like being sure the water flows, planning ahead so that infrastructure is sturdy enough to sustain blows, and communicating clearly so town residents knew what was expected of them and where to go if they had concerns.
His values were people-focused, pragmatism, preparedness, and transparency.
Those values speak compellingly to the work of oversight and compliance. They are front-of-mind for me as an Inspector General. And I believe they are values shared by the compliance community that can guide the work we do, collectively, to improve our Nation’s health care system.
This morning, I want to first update you on our OIG Modernization Initiative.
Then I want to talk about some of the work we are doing that is infused with Mack’s four core values.
First, the update on the modernization initiative. OIG’s modernization initiative aims to enhance the accessibility and usability of OIG’s publicly available data and information. We are investing resources to make program integrity and compliance easier across the health care industry. The modernization initiative builds on OIG’s long history of providing information and guidance to the health care industry. As the health care compliance profession began taking shape in the 1990s, OIG recognized the demand for more information and that the developing compliance profession could put more guidance to good use. Since then, OIG and the compliance community have worked closely together—and this partnership has always paid dividends.
The modernization initiative started in 2021 with a needs assessment. We reached out to you. We asked about your needs and preferences, and how we can most helpfully modernize the program integrity and compliance information OIG provides.
We appreciate the valuable feedback that HCCA members have provided. Thank you for taking the time to attend roundtables or respond to our Request for Information. Your feedback will be invaluable to OIG’s modernization effort.
Three big takeaways from your feedback are:
First, you value OIG’s publicly available resources. That is great to hear! And you are interested in more ways to use them to educate stakeholders. We received feedback about making it easier for you to use OIG’s information for a variety of audiences and purposes. You would like more videos, podcasts, infographics, data toolkits, and Frequently Asked Questions.
Second, you would like more ways to connect the dots. It’s not enough to have the most recent audit or corporate integrity agreement (CIA). You want more information about how it fits with our other related work.

Third, you would benefit from better, more searchable data and interactive tools that help put more of our information at your fingertips, faster. For example, you said OIG’s work plan is valuable information used regularly, but we could make it even better and more useable for you.
As health care grows more complex, organizational priorities are in constant competition. You said that more, better, and up-to-date information from OIG can help keep compliance a top priority at your organizations.
We will continue to work closely with the compliance community and other stakeholders to modernize in a way that best serves the community’s needs and our shared goals.
With that update, I want to turn to the values that guide our work and some of OIG’s top priorities, starting with people-focused results. If asked, “what is most important to you about OIG’s work”, my answer is: the possibility of driving positive change in HHS programs and in the lives of th people they serve. To do this, it is critically important that we get fraudsters off the streets, protect patients from harm, find misspent funds, reduce improper payments, and ferret out mismanagement. We must ensure that taxpayer dollars are being used for their intended purposes to improve the health and well-bein of beneficiaries. This is how I think of people-focused results for the OIG.
Achieving people-focused results also means: (1) helping HHS safeguard the integrity of their programs, (2) making recommendations to improve program effectiveness and efficiency, (3) conducting work that shines light on quality of care and health disparities, and (4) helping honest providers who want to do the right thing. Our work does not end at making an arrest, issuing an audit, or publishing guidance. Those actions are starting points. We then amplify them to push for meaningful, systemic change. To make meaningful progress, we must be relentless in our focus on results.
Let me offer some examples from our enforcement portfolio.
Since March 2020, we have been laser focused on preventing, detecting, and taking swift action against COVID-19 fraud schemes. We are combating fraud that jeopardizes public health efforts. These are brazen attempts to take advantage of a pandemic and peoples’ fears. OIG and our law enforcement partners have received thousands of complaints related to COVID-19 fraud. Scams like setting up fake testing sites in parking lots just to steal people’s identity or charging patients for fake COVID-19 treatments and falsified vaccine cards. a provider billing over $100 million to a COVID-19 program for surgeries and services that never happened and did not treat COVID. We’ve also seen more traditional types of fraud, like improper bundling of laboratory tests and kickback schemes.
In response, OIG, the Department of Justice, the Pandemic Response Accountability Committee, and nearly 30 agencies have been dedicated to disrupting COVID-19 fraud schemes and protecting the people they attempt to prey on. Collectively, we are supporting the Government’s efforts to protect the over $5 trillion in Federal funds spent for COVID-19 relief and hold accountable those who attempt to unlawfully enrich themselves. At OIG, we are focused on protecting the Provider Relief Fund, the Uninsured Fund, and millions flowing to or through HHS programs.
As a further example of people-focused results, over the past decade OIG has devoted disproportionate resources toward oversight related to opioid use and abuse, which remains a terrible scourge in the lives of too many. With action from every corner of OIG, we pressed for improvements to reduce risk to patients from opioid use disorder. As a result, the number of providers prescribing suspiciously high levels of opioids to Medicare Part D patients fell from 401 in 2016 to 98 in 2020.
Sadly, overdose deaths increased during the pandemic. This increase was driven largely by illicit use of drugs like fentanyl. In response, we have broadened our focus to look at beneficiaries’ access to treatment for substance use disorder. In a recent study, we found that only 16 percent of Medicare beneficiaries with an opioid use disorder received medication treatment. We are seeing progress but there is still much work to do.
At OIG we are harnessing data and technology to detect and respond quickly to emerging fraud schemes. For instance, we recently uncovered a scheme where laboratories were billing Medicare for expensive, unnecessary, and sometimes unprovided genetic tests. On average, these tests can cost Medicare around $1,500 each. The alleged fraud in this takedown is nearly $1.4 billion, and perhaps higher.

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