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Brought to you by the Council of the Inspectors General on Integrity and Efficiency
Federal Reports
Report Date
Agency Reviewed / Investigated
Report Title
Type
Location
Department of Health & Human Services
Palmetto Government Benefits Administrator, LLC, Claimed Some Unallowable Medicare Supplemental Executive Retirement Plan III Costs Through Its Incurred Cost Proposals
During our audit period, Palmetto was a subsidiary of Blue Cross Blue Shield of South Carolina (BCBS South Carolina), whose home office is in Columbia, South Carolina. Palmetto administers Medicare operations under the MAC contracts for Medicare Parts A and B Jurisdiction 1 and Jurisdiction 11 effective October 25, 2007, and May 21, 2010, respectively, as well as other CAS-covered and FAR-covered contracts. Currently, Palmetto is the Medicare Parts A and B contractor for Jurisdictions J and M (formerly Jurisdiction 11). Palmetto also continues to perform Railroad Retirement Board contract operations under a specialty MAC contract awarded on November 27, 2012. During our audit period, CMS and BCBS South Carolina entered into an agreement called the “Advance Agreement on the Computation of Nonqualified Defined-Benefit Pension Plan Costs for Periods Beginning January 1, 2015” (agreement). This agreement allowed BCBS South Carolina to change its accounting methodology from a pay-as-you-go to an accrual method. This agreement also closed costs prior to January 1, 2015. Starting with January 1, 2015, the SERP III plan would, under the terms of the agreement, identify its segments by individual participant. These segments allocate to each of BCBS South Carolina’s Medicare subsidiaries: Palmetto; Companion Data Services, LLC; and CGS Administrators, LLC. This report addresses Palmetto’s compliance with the provisions of the Federal requirements and its Medicare contracts in claiming SERP III costs. The disclosure statement that Palmetto submits to CMS states that Palmetto uses pooled cost accounting. Medicare contractors use pooled cost accounting to calculate the indirect cost rates (whose computations include pension, postretirement benefit, SERP III, and Excess Plan costs) that they submit on their ICPs. Medicare contractors use the indirect cost rates to calculate the contract costs that they report on their ICPs. In turn, CMS uses these indirect cost rates in determining the final indirect cost rates for each contract. BCBS South Carolina sponsors a SERP III plan. The purpose of this deferred compensation plan is to supplement participants’ benefits payable under BCBS South Carolina’s retirement plans. This plan is provided to a limited group of management employees who are responsible for earnings and long-term growth of the company. BCBS South Carolina allocated costs to the Palmetto Medicare segment. Accounting MethodologiesThe Medicare contracts require Palmetto to calculate the SERP III plan costs in accordance with the FAR and CAS 412 and 413. The FAR and the CAS require that the costs for nonqualified plans be measured under either the accrual method or the pay-as-you-go method. Under the accrual method, the allowable costs are based on the annual contributions that the employer deposits into its trust fund. For nonqualified plans that are not funded through the use of a funding agency, costs are to be accounted for under the pay-as-you-go method. This method is based on the actual benefits paid to participants, which are comprised of lump-sum payments and annuity payments. Palmetto claimed SERP III plan costs on an accrual basis. At CMS’s request, the Defense Contract Audit Agency (DCAA) and CliftonLarsonAllen, LLP (Allen), performed audits of the ICPs that Palmetto submitted for CYs 2015 and 2016. The objectives of these ICP audits were to determine whether costs were allowable in accordance with applicable Federal regulations.
During our audit period, Palmetto was a subsidiary of BCBS South Carolina, whose home office is in Columbia, South Carolina. Palmetto administers Medicare operations under the MAC contracts for Medicare Parts A and B Jurisdiction 1 and Jurisdiction 11 effective October 25, 2007, and May 21, 2010, respectively, as well as other CAS-covered and FAR-covered contracts. Currently, Palmetto is the Medicare Parts A and B contractor for Jurisdictions J and M (formerly Jurisdiction 11). Palmetto also continues to perform Railroad Retirement Board contract operations under a specialty MAC contract awarded on November 27, 2012. During our audit period, CMS and BCBS South Carolina entered into an agreement called the “Advance Agreement On the Computation of Nonqualified Defined-Benefit Pension Plan Costs for Periods Beginning January 1, 2015” (agreement). This agreement allowed BCBS South Carolina to change its accounting methodology from a pay-as-you-go to an accrual method. This agreement also closed costs prior to January 1, 2015. Starting with January 1, 2015, the Excess Plan would, under the terms of this agreement, have three Medicare segments: (1) Palmetto, (2) Companion Data Services, LLC (CDS), and (3) Partial Medicare. This report addresses Palmetto’s compliance with the provisions of the Federal requirements and its Medicare contracts in claiming Excess Plan costs. We are addressing the Excess Plan costs claimed for the CGS Administrators, LLC (CGS), and CDS Medicare segments in separate audits. The disclosure statement that Palmetto submits to CMS states that Palmetto uses pooled cost accounting. Medicare contractors use pooled cost accounting to calculate the indirect cost rates (whose computations include pension, PRB, Supplemental Executive Retirement Plan III, and Excess Plan costs) that they submit on their ICPs. Medicare contractors use the indirect cost rates to calculate the contract costs that they report on their ICPs. In turn, CMS uses these indirect cost rates in determining the final indirect cost rates for each contract. Blue Cross Blue Shield of South Carolina Excess Plan BCBS South Carolina sponsors the Excess Plan. The purpose of the Excess Plan is to provide benefits in excess of the limits imposed by the Employee Retirement Income Security Act of 1974 for participants in the qualified defined-benefit plan. Accounting MethodologiesThe Medicare contracts require Palmetto to calculate the Excess Plan costs in accordance with the FAR and CAS 412 and 413. The FAR and the CAS require that the costs for nonqualified plans be measured under either the accrual method or the pay-as-you-go method. Under the accrual method, the allowable costs are based on the annual contributions that the employer deposits into its trust fund. For nonqualified plans that are not funded through the use of a funding agency, costs are to be accounted for under the pay-as-you-go method. This method is based on the actual benefits paid to participants, which are comprised of lump-sum payments and annuity payments. Palmetto claimed Excess Plan costs on an accrual basis.
The OIG investigated allegations that a Bureau of Reclamation (BOR) employee misused a U.S. Government purchase card. Specifically, the complaint alleged that the employee deliberately overbought supplies for a BOR office and gave the excess items to a family member for personal use or sale.We did not substantiate the allegations. We concluded that all the purchases were properly authorized and were consistent with supply requirements at the facility. We also concluded the employee did not improperly dispose of any office supplies.This is a summary of an investigative report we issued to the BOR Commissioner.
Our objective was to determine whether the U.S. Postal Service is effectively managing capital equipment at the Information Technology Center (ITC) in Eagan, MN.In January 2021, the Eagan ITC had over 4,300 capital equipment items — such as computer servers — for operations, system enhancements, equipment replacement, or research and development. During calendar years 2019 and 2020, 628 items with an estimated value of $77 million were entered as capital equipment records.
In this audit, we examined NASA’s development of next-generation spacesuits for ISS and Artemis missions, specifically the extent to which the Agency is addressing cost, schedule, and performance challenges.
Since 1975, the Postal Service has leveraged its expansive retail network to accept passport applications on behalf of the U.S. Department of State (State Department). The State Department is primarily responsible for nationwide passport services. This includes designating entities to accept passport applications, providing passport information to the public, issuing U.S. passports, and ensuring program integrity. The Postal Service’s role is to accept passport applications at designated facilities, ensure all application documents are correct, and submit documents to the State Department. The Postal Service and State Department have an interagency agreement that governs passport acceptance. Our objective was to assess the Postal Service’s passport application acceptance operations and identify opportunities for improvement.
The NASA Office of Inspector General found the Agency appropriately managed those funds to meet congressional mandates as well as federal and Agency guidance.
This Office of Inspector General (OIG) Comprehensive Healthcare Inspection Program report provides a focused evaluation of the quality of care delivered in the inpatient and outpatient settings of the Sheridan VA Medical Center and multiple outpatient clinics in Wyoming. The inspection covers key clinical and administrative processes associated with promoting quality care. For this inspection, the areas of focus were Leadership and Organizational Risks; COVID-19 Pandemic Readiness and Response; Quality, Safety, and Value; Registered Nurse Credentialing; Mental Health: Emergency Department and Urgent Care Center Suicide Risk Screening and Evaluation; Care Coordination: Inter-facility Transfers; and High-Risk Processes: Management of Disruptive and Violent Behavior.At the time of the OIG review, the leadership team had worked together for over two years. The Director, who was permanently assigned in August 2017, was the most tenured leader. Selected employee survey responses revealed satisfaction with leadership and a workplace where staff felt respected and discrimination was not tolerated. Patient experience survey results were generally higher than VHA averages for male inpatient care, but opportunities for improvement were identified for both genders in outpatient settings. Review of the facility’s accreditation findings, sentinel events, and disclosures did not identify any substantial organizational risks. The executive leaders were generally knowledgeable about selected data used in Strategic Analytics for Improvement and Learning models and factors contributing to poorly performing quality and efficiency measures.The OIG issued three recommendations for improvement in three areas:(1) Quality, Safety, and Value• Peer review committee recommendation of improvement actions(2) Registered Nurse Credentialing• Primary source verification of registered nurses’ licenses prior to appointment(3) High-Risk Processes• Disruptive behavior committee attendance