Open Recommendations

This recommendation is Sensitive But Unclassified.

The Director evaluates and determines any additional reasons for noncompliance and ensures that staff complete the required prevention and management of disruptive behavior training based on the risk level assigned to their work areas.

Develop and communicate an organization wide Supply Chain Risk Management strategy and implementation plan to guide and govern supply chain risks.

Undertake a strategic analysis of the Inspector General FISMA Metrics and the weaknesses identified in the audit, to develop a multi-year strategy and approach to include objective milestones, and resource commitments by the Department and the CIO that address the corrective actions
necessary to show steady, measurable improvements towards an effective information security program.

Work with the Federal Aviation Administrations CIO and Federal Motor Carrier Safety Administrations Information Security System Manager (ISSM), to investigate and remediate cross-site scripting vulnerabilities identified in public facing web applications.

Work and coordinate with system owners to identify and remediate weak and default authentication mechanisms within their systems and the Common Operating Environment.

Develop and implement a process to facilitate centralized monitoring, oversight (by ISSMs and their alternates) and escalation efforts to ensure the timely completion of required security awareness training and role based training for all DOT personnel leveraging an automated integrated solution(s) and dashboards.

Revise the COR Appointment Letter to require compliance with the detailed written procedures developed in response to Recommendation 1 (which required the development of procedures for the COR process, including a standard governance structure and standard communication processes among CORs to support the Primary COR function, as well as invoice review responsibilities for all types of COR and how invoices are reviewed for accuracy and completeness.)

OIG recommends that the Bureau of Administration develop and implement additional internal control procedures for monitoring to ensure that justifications and approvals for other than full and open competition are completed and approved in accordance with Federal Acquisition Regulation requirements and Office of the Procurement Executive guidance and that reviewing officials verify that the justifications include all required content.

OIG recommends that the Bureau of Administration develop and implement internal controls to ensure Contracting Officers comply with Federal Acquisition Regulation Subpart 6.305, Office of the Procurement Executive Procurement Implementation Bulletin 2014-11, and Office of Acquisitions Management Memorandum 16-16 regarding providing public notice of noncompetitive contracts and maintaining proof of public notice in contract files.

OIG recommends that the Bureau of Administration (a) determine the feasibility, practicality, and cost-effectiveness of adding functions to the new online application being developed for justifications and approvals that will automatically transfer completed justifications to the electronic contract file and also post the justifications publicly in accordance with the Competition in Contracting Act and the Federal Acquisition Regulation and (b) if determined to be feasible, practical, and cost-effective, incorporate such a function in the application.

OIG recommends that the Bureau of Administration issue guidance requiring that all contracting personnel use the newly created online application for justifications and approvals once the application has been tested and determined to meet the goals established by the Bureau of Administration.

OIG recommends that the Bureau of Administration issue a directive to the Office of Acquisitions Management to update its Quality Assurance Plan to expand the steps necessary to ensure compliance with Federal Acquisition Regulation provisions regarding preparing fair and reasonable price determinations for noncompetitive awards. The steps should include requiring that Contracting Officers use the sample template for price negotiation memoranda and retain evidence of the analysis conducted in support of such determinations in the contract files.

OIG recommends that the Bureau of Administration develop and implement guidance directing all price negotiation memoranda-approving officials certify that price negotiation memoranda address all required elements in compliance with Federal Acquisition Regulation Subpart 15.406-3 before approving them.

OIG recommends that the Bureau of Administration issue a directive to the Office of Acquisitions Management to update its Memorandum 15-09, "Contract File Documentation," regarding price negotiation memoranda. The updated memorandum should include instructions for Contracting Officers to verify that all price negotiation memoranda packages are properly approved and placed in the contract file.

OIG recommends that the Bureau of Administration develop and implement additional internal control procedures for monitoring compliance with Federal Acquisition Regulation requirements and Department policy regarding determining and documenting fair and reasonable price determinations and maintaining complete contract files.

Develop and implement root cause analysis training for inspectors more in line with training in the aviation industry.

Develop and implement a management control to ensure inspectors require air carriers to provide written root cause analyses and that these analyses do not specifically identify human factors issues as root causes.

Develop and implement Safety Management System training for inspectors that is specifically designed to aid inspectors in evaluating air carrier risk assessments.

Revise the Safety Management Systems data collection tool to allow inspectors to perform more detailed reviews and accurately document the results of these reviews.

Sensitive information redacted

We recommend that the Tennessee State Medicaid Agency refund to the Federal Government $397,341,616 in overpayments representing the Federal share of CPEs that the State agency claimed in excess of the allowable amount.

We recommend that the Tennessee State Medicaid Agency provide support for or refund to the Federal Government $370,119,499 for the net costs of caring for uninsured IMD patients for which the State agency did not provide detailed supporting documentation.

We recommend that the Tennessee State Medicaid Agency establish additional policies and procedures to ensure compliance with the STCs including policies and procedures for adjusting the CPE estimates to actual costs on the CMS-64s upon determining that hospitals have been overpaid or underpaid.

We recommend that the Tennessee State Medicaid Agency establish additional policies and procedures to ensure compliance with the STCs including policies and procedures for collecting and maintaining patient-level detail data for the uninsured population for the IMDs.