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New HHS Grant and Contract Oversight: Fraud and Mismanagement Risks, Enforcement Action, Best Practices for Compliance

A live 90-minute CLE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Wednesday, March 12, 2025 (in 1 day)

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

or call 1-800-926-7926

This CLE webinar will guide practitioners through the U.S. Department of Health and Human Services Office of Inspector General's (HHS-OIG) recently published strategic plan to more closely monitor agency grants and contracts for fraud and mismanagement. The panel will provide an overview of the grants and contracts lifecycle along with the inherent risks of abuse in each. The panel will also offer best practices for compliance to mitigate the risk of enforcement action for contractor clients.

Description

In FY 2023, HHS (excluding CMS) awarded approximately 142,000 grants totaling $148.6 billion and approximately 54,000 contracts totaling $31 billion. As fraud related to awards by HHS and other agencies continues to increase, HHS-OIG recently published a strategic plan for improving grant and contractual oversight. The agency's stated goals are to: (1) strengthen compliance with HHS award requirements throughout the grants and contracts life cycle; (2) promote award practices that achieve program outcomes; and (3) enhance public trust in HHS awards by mitigating fraud, waste, abuse, and mismanagement.

The agency acknowledges that each step in the grants and contracts lifecycle contains unique risks and vulnerabilities for fraud and mismanagement. For example, risks in the pre-award stage can include applicants seeking awards they are ineligible to receive or making financial arrangements to steer awards in their favor. Or in the post-award stage, risks include the misuse of awards due to inefficiencies, the claiming of unallowable expenditures, or fraud.

Therefore, the agency has created objectives for each of the stated goals to improve agency oversight including, for mitigating fraud and mismanagement, the increased use of criminal, civil, and administrative actions; suspension and debarment referrals; and follow-up of unimplemented recommendations.

Counsel should understand the agency's new guidance to assist their healthcare contractor clients with strict compliance and to minimize the risk of costly enforcement action.

Listen as our expert panel discusses HHS-OIG's strategic plan for the increased oversight of HHS-awarded grants and contracts. The panel will provide an overview of the grants and contracts lifecycle and risks of fraud and mismanagement in each. The panel will then discuss the agency's objectives for mitigating those risks, including possible enforcement action, and offer best practices for compliance to mitigate the risk of noncompliance.

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Outline

  1. Introduction
    1. Purpose of HHS' new initiative
  2. Grants and contracts lifecycle and fraud/mismanagement risks inherent to each
    1. Pre-award
    2. Award
    3. Post-award
    4. Closeout
  3. Strategic plan: safeguarding the integrity of HHS grants and contracts
    1. Goals and objectives
      1. Strengthen compliance with requirements throughout the grants and contracts lifecycle
      2. Promote award practices that achieve program outcomes
      3. Enhance public trust in HHS awards by mitigating fraud, waste, abuse, and mismanagement
    2. Contractor compliance considerations
    3. Enforcement
  4. Lessons learned from recent high profile enforcement fraud actions
  5. Practitioner takeaways

Benefits

The panel will review these and other important considerations:

  • What is the purpose of HHS-OIG's strategic plan for increasing oversight of agency grants and contracts?
  • What vulnerabilities in the grants and contracts lifecycle increase the risk of fraud and mismanagement?
  • What are the agency's objectives in reducing the risk of fraud and mismanagement in the grants and contracts lifecycle? And what types of enforcement action may it use to reach those objectives?

Faculty

Castronova , Andrea
Andrea Castronova

Principal
Athena Compliance Partners

Ms. Castronova has over 25 years of experience in healthcare compliance and internal audit. She provides various...  |  Read More

Sapien-Pangindian, Dennis
Dennis Sapien-Pangindian

Senior Counsel
Epstein Becker & Green

As a litigation and regulatory attorney, Mr. Sapien-Pangindian draws on his enforcement experience at the U.S. HHS OIG...  |  Read More

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