Federal Reports

The Hospital complied with Medicare billing requirements for 54 of the 100 inpatient and outpatient claims we reviewed. However, the Hospital did not fully comply with Medicare billing requirements for the remaining 46 claims, resulting in overpayments of $1.6 million for the audit period. Specifically, 45 inpatient claims and 1 outpatient claim had billing errors.

The Department designed its review and approval processes to provide reasonable assurance that it would identify and resolve potential instances of State plans’ noncompliance with the ESEA and McKinney-Vento Act requirements subjected to peer review. The Department also designed the review and approval processes to provide reasonable assurance that it complied with selected ESEA and McKinney-Vento Actrequirements and Department policy. Although the Department implemented its plans for providing guidance to peer reviewers and States and implemented its peer review process in a manner that provided reasonable assurance of State plans’ compliance with ESEA and McKinney Vento Act requirements, we found that the Department did not implement all aspects of the review and approval processes as designed. The The Department did not (1) always retain records that ensured adequate and proper documentation of its peer reviewer selection decisions or its analysis of peer reviewer comments on the McKinney-Vento Act requirements of State plans, (2) publish all versions of States’ plans on its website, or (3) always show that it considered conflict of interest information collected from peer reviewers before assigning them to panels. We did not identify any evidence that would suggest that the Department acted outside its authority to disapprove a State plan as set forth in section 1111(a)(4)(A)(vi) of the ESEA. However, because of the issues noted above, we could not determine why the Department selected certain peer reviewers. We also could not always determine whether the Department considered the results of the peer review process whenproviding feedback on the McKinney-Vento Act section of State plans. Finally, we could not ensure that the Department considered conflict of interest information it collected from peer reviewers before assigning them to panels, which could affect the integrity of the peer review processes.

The Department designed policies and procedures for awarding and monitoring discretionary grants through its Discretionary Grant Handbook. Additionally, the Department designed risk mitigation strategies specific to the Defraying Costs and Emergency Assistance programs through the Internal Control Plan. Together, these policies and procedures, as designed, should have provided reasonable assurance that the Department awarded and monitored grantees’ uses of Defraying Costs and Emergency Assistance grants in accordance with the Bipartisan Budget Act, Uniform Guidance, and Department policy. We concluded that OPE did not implement all the relevant Discretionary GrantHandbook processes and Internal Control Plan risk mitigation strategies as designed. Specifically, OPE did not (1) scrutinize costs in all applications and eliminate those costs that were unallowable; (2)validate grantees’ self-reported data; (3) prepare appropriate terms, such as a high-risk designation and associated conditions, for any awards made to grantees it designated as high risk; (4) apply its Emergency Assistance program allocation formula as designed; (5)conduct post-award conferences; (6) complete post-award monitoring; (7) support changes made through administrative action grant award notifications; and(8) retain all relevant records in official Emergency Assistance grant files.