Open Recommendations

We recommend the TSA Chief Information Officer direct the selected High Value Asset system owner to enforce users to receive security awareness training when they are given system access and annually thereafter.

We recommend the TSA Chief Information Officer direct the selected High Value Asset system owner to strengthen its system-level Information Security Continuous Monitoring by ensuring (1) security documents contain current and accurate information about the system; (2) relevant policies and procedures are developed, reviewed, and approved; and (3) Plans of Action and Milestones are remediated promptly and include all required information.

We recommend the TSA Chief Information Officer require the selected High Value Asset System’s Contingency Plan and Contingency Plan Test to be reviewed and approved in accordance with DHS and National Institute of Standards and Technology guidance.

We recommend that the Chief Operating Officer for Federal Student Aid (FSA) require USC to— 1.1 Calculate the actualamount of improper Pell and any other Title IV payments made to the 13 students for whom it did not apply professionaljudgment other than dependency override in accordance with section 479A of the HEA and return those funds to theDepartment.

We recommend that the Chief Operating Officer for Federal Student Aid (FSA) require USC to— 1.2 Review its records forthe 6,062 students for whom the school reported that it applied professional judgment other than dependency override foraward year 2019–2020 or award year 2020–2021 but were not included in our sample and (a) identify those students forwhom it improperly adjusted the value of data items affecting AGI based on allowances or expenses unrelated to specialcircumstances, (b) provide FSA with a listing of the improperly disbursed Title IV funds and the records associated withthose students for whom financial aid administrators improperly applied…

We recommend that the Chief Operating Officer for FSA require USC to— 2.1 Review its records for the 6,162 studentsfor whom the school reported that it applied professional judgment other than dependency override for award year2019–2020 or 2020–2021; identify records adequately documenting the use of professional judgment; and provide therecords for any students with inadequately documented professional judgment to FSA along with a listing of the amount ofTitle IV funds, if any, that were improperly awarded and disbursed to students.

We recommend that the Chief Operating Officer for FSA require USC to— 3.1 Provide additional records that adequatelydocument the financial aid administrators’ determinations of independence for the six students or return to the Department$3,700 in Pell funds and $26,200 in Direct Loan funds.

We recommend that the Chief Operating Officer for FSA require USC to—Review its records for the 81 students notincluded in our sample; identify records adequately documenting the financial aid administrators’ determinations ofindependence; and provide the records for any students with inadequately documented dependency override to FSA alongwith a listing of the amount of Title IV funds, if any, that the school improperly awarded and disbursed to the students.

We recommend that the Chief Operating Officer for FSA require USC to— 4.1 Develop and implement procedures forconfirming that its student information system data are corroborated by its financial assistance records before reportingthe use of professional judgment to the Department’s Central Processing System.

We recommend that the FEMA Administrator resolve questioned costs totaling an estimated $24,438,662 for expenses deemed ineligible by FEMA’s Individual Assistance Program and Policy Guide and determine the amount of any debts owed by recipients for erroneous payments.

We recommend that the FEMA Administrator ensure that future iterations of the Individual Assistance Program and Policy Guide and supporting procedures (a) provide consistent guidance on eligibility of funeral expenses for all future disaster declarations; and (b) allow for reimbursement of only necessary expenses and serious needs, consistent with the law.

We recommend that the FEMA Administrator ensure that FEMA provides its COVID-19 Funeral Assistance call center contractor the guidance and training necessary to meet the quality control and production monitoring metrics as prescribed by its agreement with the contractor.

We recommend that the Office of Insular Affairs work with the U.S. Virgin Islands Department of Finance to revise the Department of Finance Standard Operating Procedure 604 to include all methods of allocating compensation costs by documenting responsibilities and procedures for determining the allocation.

We recommend that the Office of Insular Affairs work with the U.S. Virgin Islands Department of Finance to develop and implement written procedures for determining cost allowability and for reviewing drawdown requests.

We recommend the Executive Associate Director for Homeland Security Investigations develop and implement a work plan detailing prioritized upgrades to the Repository for Analytics in a Virtualized Environment, Data Analysis & Research for Trade Transparency System, estimated funding requirements for those upgrades, and timelines for implementing the upgrades. The upgrades should include processes to achieve program objectives and respond to program risks such as capabilities to facilitate identifying trade-based money laundering transactions.

We recommend the Executive Associate Director for Homeland Security Investigations conduct an analysis of the Trade Transparency Unit workforce to determine the number of full-time staff needed to accomplish the unit’s mission and convey those requirements to the Office of the Chief Financial Officer for future funding consideration.

USDA OIG has determined that this recommendation contains sensitive information and will not be publicly released due to privacy concerns.

USDA OIG has determined that this recommendation contains sensitive information and will not be publicly released due to privacy concerns.

USDA OIG has determined that this recommendation contains sensitive information and will not be publicly released due to privacy concerns.

USDA OIG has determined that this recommendation contains sensitive information and will not be publicly released due to privacy concerns.

We recommend that the Centers for Medicare & Medicaid Services instruct MACs to implement edits in their claims processing systems to prevent an OTP from being paid for: (1) a weekly bundle with a service date that was within a contiguous 7-day period of another weekly bundle's service date for the same enrollee at the same OTP or (2) two weekly bundles with the same service date for the same enrollee at the same OTP.

We recommend that the Centers for Medicare & Medicaid Services work with MACs to determine whether claims billed by OTPs for OUD treatment services complied with Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services work with MACs to provide education on proper billing of intake activities to the 8 OTPs that billed 14 or more intake activity claims per enrollee during our audit period.

We recommend that the Centers for Medicare & Medicaid Services revise its billing guidance to specify that OTPs should not bill add-on HCPCS codes for take-home supplies of medication for the same episode of care that was already covered by a weekly bundle that included medication, and instruct MACs to implement edits in their claims processing systems to identify improperly billed claims for take‑home medication.

We recommend that the Centers for Medicare & Medicaid Services instruct MACs, based upon the results of this audit, to notify appropriate providers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the providers can exercise reasonable diligence to identify, report, and return any overpayments, up to $17,817,121, in accordance with the 60-day rule and identify any of those returned overpayments as having been made in accordance with this recommendation.