Audit of Defense Health Agency Controls to Monitor Opioid Prescription Compliance with Federal and DoD Opioid Safety Standards

Submitting OIG:

Department of Defense OIG

Date Issued:

Thursday, December 7, 2023

Agency Reviewed / Investigated:

Department of Defense

Submitting OIG-Specific Report Number:

DODIG-2024-036

Location(s):

Agency-Wide

Type of Report:

Audit

Questioned Costs:

Funds for Better Use:

Report updated under NDAA 5274:

View Document:

Attachment	Size
DODIG-2024-036-SECURE.pdf	4.22 MB

Recommendation Number	Recommendation Status	Significant Recommendation
D-2024-0036-D000AX-0001-0001.a	Open	No
Rec. 1.a: The DoD OIG recommended that the Director of the Defense Health Agency review the nine at-risk beneficiaries to determine whether providers followed or met Federal and DoD opioid safety recommendations and requirements and justified a medical need to provide the high level of opioid dosages. In instances where providers cannot justify a medical need to not follow or meet recommendations and requirements, hold the providers accountable for non‑compliance with requirements and review instances where they did not follow recommendations, while also reviewing a broader sample of those providers' beneficiaries to identify additional instances where they did not follow recommendations or meet requirements.
D-2024-0036-D000AX-0001-0001.b	Open	No
Rec. 1.b: The DoD OIG recommended that the Director of the Defense Health Agency implement procedures to review whether DoD medical treatment facility and Managed Care Support Contractor personnel are following and meeting Federal and DoD opioid safety recommendations and requirements. Specifically, the Defense Health Agency should ensure providers: 1. Complete informed consent covering the risks and benefits of opioid therapy and ensure DoD medical treatment facilities are distributing Defense Health Agency standardized informed consent forms to beneficiaries receiving opioid prescriptions. 2. Perform Prescription Drug Monitoring Program checks at least every 3 months. 3. Provide or refer beneficiaries for care in the tertiary level of the Military Health System Stepped Care Model. 4. Follow up with beneficiaries to evaluate the benefits and potential harms of continued opioid use at least every 3 months and within 1 to 4 weeks of dose escalation. 5. Monitor beneficiaries' opioid use through urine drug testing at least annually. 6. Pursue tapering opioid use to a reduced dose or to discontinuation, where appropriate.
D-2024-0036-D000AX-0001-0002.a	Open	No
Rec. 2.a: The DoD OIG recommended that the Director of the Defense Health Agency determine whether the five sample beneficiaries who were not listed on Prescription Monitoring Program reports should have been identified as candidates through the Prescription Monitoring Program and, based on the results, coordinate with the TRICARE Pharmacy contractor to determine whether the algorithms used to identify candidates on the Prescription Monitoring Program are adequate to identify all at‑risk beneficiaries on long-term opioid therapy and receiving high morphine milligram equivalents. If the Defense Health Agency determines the algorithms are not adequate, the Defense Health Agency should coordinate with the TRICARE Pharmacy contractor to adjust the algorithms to ensure they identify all at-risk beneficiaries on long-term opioid therapy and receiving high morphine milligram equivalents.
D-2024-0036-D000AX-0001-0002.b	Open	No
Rec. 2.b: The DoD OIG recommended that the Director of the Defense Health Agency increase the number of required Prescription Monitoring Program candidate reviews for the Managed Care Support Contractors, while also implementing standard Prescription Monitoring Program processes and review requirements for all DoD medical treatment facilities to include the number of candidates to review.
D-2024-0036-D000AX-0001-0002.c	Open	No
Rec. 2.c: The DoD OIG recommended that the Director of the Defense Health Agency implement procedures to review DoD medical treatment facility and Managed Care Support Contractor compliance with the Prescription Monitoring Program requirements in Defense Health Agency Instructions and the TRICARE Operations Manual.
D-2024-0036-D000AX-0001-0003.a	Open	No
Rec. 3.a: The DoD OIG recommended that the Director of the Defense Health Agency review the 10 beneficiaries with insufficient medical documentation to determine whether providers followed or met Federal and DoD opioid safety recommendations and requirements and justified a medical need to provide the high level of opioid dosages and determine whether the beneficiaries need additional medical assistance. In instances where providers cannot justify a medical need to not follow or meet recommendations and requirements, hold the providers accountable for non-compliance with requirements and review instances where they did not follow recommendations, while also reviewing a broader sample of those providers' beneficiaries to identify additional non-compliance.
D-2024-0036-D000AX-0001-0003.c	Open	No
Rec. 3.c: The DoD OIG recommended that the Director of the Defense Health Agency develop and implement a process to obtain medical documentation for DoD beneficiaries from DoD medical treatment facilities and other agencies or health insurance providers to support routine monitoring and medical reviews of at‑risk beneficiaries.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

D-2024-0036-D000AX-0001-0001.a

Open

Rec. 1.a: The DoD OIG recommended that the Director of the Defense Health Agency review the nine at-risk beneficiaries to determine whether providers followed or met Federal and DoD opioid safety recommendations and requirements and justified a medical need to provide the high level of opioid dosages. In instances where providers cannot justify a medical need to not follow or meet recommendations and requirements, hold the providers accountable for non‑compliance with requirements and review instances where they did not follow recommendations, while also reviewing a broader sample of those providers' beneficiaries to identify additional instances where they did not follow recommendations or meet requirements.

D-2024-0036-D000AX-0001-0001.b

Open

Rec. 1.b: The DoD OIG recommended that the Director of the Defense Health Agency implement procedures to review whether DoD medical treatment facility and Managed Care Support Contractor personnel are following and meeting Federal and DoD opioid safety recommendations and requirements. Specifically, the Defense Health Agency should ensure providers: 1. Complete informed consent covering the risks and benefits of opioid therapy and ensure DoD medical treatment facilities are distributing Defense Health Agency standardized informed consent forms to beneficiaries receiving opioid prescriptions. 2. Perform Prescription Drug Monitoring Program checks at least every 3 months. 3. Provide or refer beneficiaries for care in the tertiary level of the Military Health System Stepped Care Model. 4. Follow up with beneficiaries to evaluate the benefits and potential harms of continued opioid use at least every 3 months and within 1 to 4 weeks of dose escalation. 5. Monitor beneficiaries' opioid use through urine drug testing at least annually. 6. Pursue tapering opioid use to a reduced dose or to discontinuation, where appropriate.

D-2024-0036-D000AX-0001-0002.a

Open