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Brought to you by the Council of the Inspectors General on Integrity and Efficiency
From July 1, 2016, through December 31, 2018 (audit period), Medicare paid approximately $4 billion for orthotic braces provided to Medicare beneficiaries. Prior OIG audits found that some suppliers of durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) billed for orthotic braces that did not comply with Medicare requirements. During our audit period, the Centers for Medicare & Medicaid Services found that orthotic braces were among the top 20 DMEPOS items with the highest improper payment rates. After analyzing Medicare claim data, we selected for audit Freedom Orthotics, Inc. (Freedom), an orthotic braces supplier in Dunedin, Florida.
Under the Wildlife and Sport Fish Restoration Program (WSFR), the U.S. Fish and Wildlife Service (FWS) provides grant funds to eligible States to conserve, restore, and manage wildlife and sport fish resources. States may provide WSFR funds in the form of a subaward to other non-Federal entities, such as universities, to accomplish grant objectives.The National Bobwhite Conservation Initiative (NBCI) at the University of Tennessee provides data and tools to various States and external partners (such as nongovernmental organizations) to restore wild populations of bobwhite quail. State fish and wildlife agencies fund the NBCI through WSFR subawards and State hunting and fishing license revenues. The NBCI also receives subawards from external partners and direct grants from other non-FWS Federal agencies.This management advisory (1) summarizes our findings about NBCI cost allocation during audit periods prior to the NBCI’s 2017 implementation of a recharge center accounting methodology, (2) presents our determination why the currently used recharge center is not compliant with Federal regulations and WSFR guidelines, and (3) presents a potential opportunity for the NBCI to continue its work in a way that complies with Federal regulations.We make three recommendations to the FWS that address the NBCI’s compliance with Federal regulations and an additional recommendation that the FWS identify any other programs that have similar issues.
CARES Act Section 3610 allows Federal agencies to reimburse their contractors and subcontractors for any paid leave, including sick leave, that the contractors provide to keep their employees or subcontractors in what the section refers to as a “ready state.” Because these reimbursements present a number of risks and the U.S. Department of the Interior (DOI) is already receiving Section 3610 claims from contractors, the DOI urgently needs to put policies in place to ensure consistent oversight of reimbursed leave costs.In this management advisory memorandum, we offer three recommendations that, if implemented, will help the DOI prevent fraud, waste, and abuse related to costs reimbursed under Section 3610.