Federal Reports

The objective for this report was to assess the extent to which the company has taken steps to determine employees’ current perspectives on safety. We issued this report to provide our findings on a potential issue the company could address in the near term.We found that the company has not established a baseline measure of its own safety culture which is necessary to track its progress in improving its safety culture as a result of its investment in the SMS. According to a joint U.S. Department of Transportation (DOT) and Federal Railroad Administration study, as well as industry research, a primary method of establishing such a baseline is surveying employees’ values, attitudes, and perceptions about safety and the organization’s actions to improve it. We recommended the company develop and deploy an employee survey based on the DOT’s ten elements of a strong safety culture. The survey should be conducted in conjunction with planned training, or as soon as practical without delaying training. We also recommended the company use the survey’s results to measure its progress in improving safety culture over time and take action to address additional issues the survey identifies.

In 2010, Congress passed the Patient Protection and Affordable Care Act (ACA). The ACA established enhanced Federal reimbursement rates for services provided to nondisabled, low-income adults without dependent children (new adult group). The enhanced reimbursement rates established under the ACA have raised concerns about the possibility that States could improperly enroll individuals for Medicaid coverage in the new adult group and, as a consequence, the potential for improper payments.Our objective was to determine whether Colorado properly claimed reimbursement for Medicaid services provided from January 1, 2014, through September 30, 2015, to beneficiaries who were enrolled in the new adult group but who later became ineligible for Medicaid coverage.

BACKGROUNDThe Medicare ProgramTitle XVIII of the Social Security Act (the Act) established the Medicare program, which provideshealth insurance coverage to people aged 65 and over, people with disabilities, and people withend-stage renal disease. The Centers for Medicare & Medicaid Services (CMS) administers theMedicare program. Medicare Part B provides supplementary medical insurance for medicaland other health services, including critical care services performed by physicians. CMScontracts with Medicare administrative contractors (MACs) to process and pay Part B claims.Medicare Coverage of Critical Care ServicesCritical care is defined as medical care delivered directly by a physician or a qualified nonphysicianpractitioner for a critically ill or critically injured patient. A critical illness or injury isone that acutely impairs one or more vital organ systems such that there is a high probability of imminent or life-threatening deterioration in the patient’s condition. Critical care involves highcomplexity decision making to assess, manipulate, and support vital system functions to treatsingle or multiple vital organ system failure and prevent further life-threatening deteriorationof the patient's condition (HCPCS [Healthcare Common Procedure Coding System] and CPTCodebook 2016–2018, and CMS, Medicare Claims Processing Manual, Pub. No. 100-04,Chapter 12, § 30.6.12.A (the Manual)).The time that can be reported as critical care is the physician time spent engaged in workingdirectly related to the individual patient's care. That time must be spent either at the patient’simmediate bedside or elsewhere on the floor or unit as long as the physician is immediatelyavailable to the patient. When the physician is providing critical care services, he or she mustdevote his or her full attention to the patient and cannot provide services to any other patientduring the same period (HCPCS and CPT Codebook 2016–2018, and the Manual, Chapter 12,§ 30.6.12.C).Critical care is a time-based service. CPT code 99291 is used to bill for the first 30 to 74 minutesof critical care on a given date of service by a physician or physician group of the samespecialty. CPT code 99292 is used to bill for additional blocks of time of up to 30 minutes eachbeyond the first 74 minutes of critical care occurring on the same date. Critical care that is lessthan 30 minutes in total duration on a given date should be reported using another appropriateevaluation and management (E&M) code (HCPCS and CPT Codebook 2016–2018, and theManual, Chapter 12, § 30.6.12.F). See the Figure on the following page for an explanation ofhow to code critical care services according to the amount of time spent providing critical care.Medicare Requirements for Identifying and Returning OverpaymentsClinical Practices of the University of PennsylvaniaClinical Practices is the faculty practice group for the University of Pennsylvania PerelmanSchool of Medicine’s clinical departments. Clinical Practices has locations throughout thePhiladelphia, Pennsylvania, metropolitan area and includes physicians in 59 different medicalspecialties and sub-specialties. Clinical Practices operates as a University of Pennsylvaniadivision and is responsible for operating the Perelman School of Medicine faculty’s clinicalpractices, as well as other University of Pennsylvania Health System clinical practices. Duringour audit period, Novitas Solutions was the MAC that processed and paid Clinical Practices’claims.

On October 5, 2018, the President signed into law the GDA as part of the FAA Reauthorization Act of 2018 (P.L. No. 115-254, Subtitle F). The purpose of the GDA is to foster efficient administration of geospatial data, technologies, and infrastructure by improving the coordination and partnerships between the producers and consumers of geospatial information in Federal, State, Tribal, and local governments, the private sector, and academia. Additionally, the GDA is intended to reduce duplicative efforts to procure geospatial data, services, expertise, and technology within the Federal Government. To facilitate efficient geospatial activities in the Federal Government, the GDA formalizes geospatial-related committees and governance processes. Additionally, the GDA codifies portions of OMB Circular No. A-16, Coordination of Geographic Information, and Related Spatial Data Activities, and the tools used to develop, drive, and manage the National Spatial Data Infrastructure (NSDI).

What We Looked AtGeospatial data contain information on locations on Earth, such as location identifiers and boundary characteristics. Transportation related geospatial data include instrument-flight-rule navigation charts and maps of pipeline inspection boundaries. In October 2018, Congress passed the Geospatial Data Act (GDA) on the management of the National Spatial Data Infrastructure (NSDI). NSDI includes 17 geospatial data themes, including a transportation theme. The act requires inspectors general of covered agencies to report to Congress on their agencies’ geospatial data. Our audit objective was to assess DOT’s progress in fulfilling the act’s requirements. Specifically, we reviewed the Department’s status in implementing its responsibilities (1) as a lead covered agency under section 756 and (2) as a covered agency under sections 759(a) and 759(b). What We FoundDOT has implemented two of five responsibilities under section 756—communicating with theme users about data needs and designating a point of contact for the GeoPlatform. It has partially completed a third. DOT has not yet developed standards for the National Geospatial Data Asset (NGDA) in the transportation theme, and does not have complete information about financial resources needed for transportation theme maintenance.DOT is making progress implementing 11 responsibilities as a covered Agency under section 759(a), with 4 complete and 4 partially complete. For example, DOT is updating its Geospatial Information System Strategic Plan—its strategy for promoting use of geographic information. While it is addressing the act’s reporting requirements under section 759(b), DOT has not collected information needed for an annual report. DOT also does not have a complete inventory of geospatial data assets but is updating its data inventory guidelines, which will explain how Operating Administrations should inventory and verify the accuracy of their geospatial data. RecommendationsDOT concurred with all 13 recommendations to help it comply with the act’s requirements and provided documentation to close 1 recommendation.

The U.S. Department of Housing and Urban Development (HUD), Office of Inspector General, audited HUD’s Office of Multifamily Housing Programs upon receiving a hotline complaint. The hotline complaint contained allegations that (1) HUD routinely fails to perform Endangered Species Act analysis or consultations; (2) there are many projects that have deficiencies in noise analysis and environmental assessment site factors; (3) the environmental reviews for projects with fewer than 200 units are not performed properly; and (4) there is no oversight for projects with fewer than 200 units, and there are no safeguards for checking reviews for projects with fewer than 200 units. Our objective was to determine whether (1) the complainant’s allegations were substantiated for the 8 properties reviewed and (2) the Office of Multifamily Housing Programs properly followed mitigation requirements for the 17 properties reviewed.We partially substantiated allegation 3 and incorporated that issue into the finding. We were not able to substantiate the other allegations. HUD did not always properly follow mitigation requirements for its Federal Housing Administration-insured multifamily projects. Specifically, HUD did not always identify required mitigation measures or upload mitigation resolutions into the HUD Environmental Review Online System (HEROS) to document completion of its projects. Additionally, HUD did not conduct the required radon mitigation for one of its projects before final endorsement. This condition occurred because the multifamily HEROS users lacked training, HUD did not have procedures in place, and radon requirements were not updated on the closing documents. As a result, HUD was at risk of not conducting all required measures to mitigate conditions that would endanger the health and safety of its multifamily residents and lacked assurance that the new radon requirements were properly followed before the checklist update for the final endorsement closing documents.We recommended that the Deputy Assistant Secretary for Multifamily Housing (1) conduct and make available internal HEROS training for all multifamily HEROS users on how to document the environmental review mitigation measures, (2) establish and implement written procedures specifying which multifamily employees are required to upload mitigation resolutions after construction completion and at final endorsement, (3) upload the 17 missing mitigation resolutions and the 1 missing radon testing document into HEROS for the projects in this finding, (4) Strengthen HEROS or internal procedures to add an additional requirement confirming that the mitigation resolutions have been uploaded at final endorsement, and (5) strengthen HEROS by adding a column on the dashboard to show the progress of the overall mitigation status.

Our objective was to determine if the Postal Service’s Automated Delivery Unit Sorter (ADUS) achieved projected cost savings. The Postal Service has deployed a wide range of automated sorting equipment to achieve cost savings associated with reducing less-efficient manual processing and enhancing productivity. The ADUS is one of its most recent efforts, automating the sorting of smaller packages (up to 30 pounds) in delivery units and small processing and distribution centers (P&DC). Postal Service management issued two Decision Analysis Reports (DAR) in fiscal years (FY) 2017 and 2018 for the purchase and deployment of 20 ADUS machines for a combined [redacted]. These machines were installed at 10 delivery units and 10 small P&DCs across the country and were projected to capture cost savings of $8.8 million in FYs 2018 and 2019.