GAO Urges Better Tracking of COVID-19’s Impact on HCBS

The U.S. Government Accountability Office (GAO) recently issued a report studying the temporary changes approved by the Centers for Medicare & Medicaid Services (CMS) to allow for safer provision of HCBS during the COVID-19 pandemic.

In its report, the GAO interviewed Medicaid officials from CMS and looked at CMS’ pandemic plans and federal internal control standards. The GAO found CMS provided limited guidance and reporting mechanisms for states to monitor changes and share data. The report concluded that while the temporary measures, including provision of telehealth, did allow for more patient contact without viral transmission, other long-term challenges were left unaddressed.

According to the report:

• CMS relied on states to monitor during the emergency. CMS has no procedures for monitoring temporary changes during an emergency. Instead, states had the primary responsibility to monitor the effects of temporary changes during the COVID-19 emergency, according to CMS officials. CMS provided limited guidance to states on monitoring the changes, and did not request that states share any data, such as COVID-19 infections or deaths, with CMS. Without developing monitoring procedures in advance of future public health emergencies, CMS is unlikely to conduct necessary monitoring.
• CMS’s plan for evaluating after the emergency is unclear. CMS officials told GAO that they intend to evaluate temporary changes made to HCBS programs, but had not developed plans to do so. Officials said they will continue to review regular state reporting on steps taken to ensure the overall quality of HCBS programs. However, this reporting may not provide useful information for evaluating how temporary changes affected access to HCBS or the prevention of disease spread, and some reports are not due for more than 3 years. Without a full evaluation, CMS may miss opportunities to better prepare for future emergencies.

GOA made two overarching recommendations to CMS:

1. Develop procedures to monitor temporary changes to HCBS programs during public health emergencies; and
2. Evaluate the temporary changes after the COVID-19 emergency and address opportunities for improvement.

The Department of Health and Human Services concurred with GAO’s recommendations.