Open Recommendations

2. We recommend that Alta Bates Summit Medical Center based on the results of this audit, exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule, and identify any of those returned overpayments as having been made in accordance with this recommendation.

3. We recommend that Alta Bates Summit Medical Center strengthen controls to ensure that: (1) all IRF beneficiaries meet Medicare criteria for acute inpatient rehabilitation and all required documentation is included in the medical records, (2) procedure and diagnosis codes are supported in the medical records and staff are properly trained, (3) all inpatient beneficiaries meet Medicare requirements for inpatient hospital services, (4) the use of bypass modifiers is supported in the medical records, and (5) staff are properly trained.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE strengthens its policy for creating and retaining records so those records demonstrate adequate and proper documentation of OESE’s functions, policies, decisions, procedures, and essential transactions relevant to the review and approval of the McKinney-Vento Act section of State plans.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE makes publicly available all submissions and resubmissions of States’ plans, including individual and consolidated plans, to promote full transparency.

We recommend that the Assistant Secretary for Elementary and Secondary Education ensure that OESE adheres to its policy and considers all conflict of interest information collected from peer reviewers before assigning them State plans to review.

Rec. 1.a: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Assistant Secretary of Defense for Health Affairs and Secretaries of the Military Departments, establish a working group within 30 days of this report's publication, to address the personnel, supplies, testing capabilities, information technology, communication, and lines of authority challenges that we identified during the Coronavirus Disease-2019 pandemic that exist between the Services and the Defense Health Agency. The working group should establish milestones to develop guidance for coordinating the staffing of multi-Service military treatment facilities during a pandemic.

Rec. 1.d: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Assistant Secretary of Defense for Health Affairs and Secretaries of the Military Departments, establish a working group within 30 days of this report's publication, to address the personnel, supplies, testing capabilities, information technology, communication, and lines of authority challenges that we identified during the Coronavirus Disease-2019 pandemic that exist between the Services and the Defense Health Agency. The working group should establish milestones to issue clarifying guidance for defining essential personnel for civilian healthcare workers.

Rec. 1.e: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Assistant Secretary of Defense for Health Affairs and Secretaries of the Military Departments, establish a working group within 30 days of this report's publication, to address the personnel, supplies, testing capabilities, information technology, communication, and lines of authority challenges that we identified during the Coronavirus Disease-2019 pandemic that exist between the Services and the Defense Health Agency. The working group should establish milestones to update contracts to allow for more flexibility regarding the use of contracted personnel during extenuating circumstances…

The Bureau of European and Eurasian Affairs should review and de-obligate any of the unliquidated obligations totaling $3.3 million without activity for over 1 year and put de-obligated funds to better use.

Ensure that all case file documents are accurately timestamped to the date they are actually completed and that all staff are trained on how to properly maintain accurate and up-to-date case files

Strengthen existing procedures to ensure that family reunification packets are sent within required timeframes

Develop policies and procedures for promptly notifying DHS of the imminent release of a child to a sponsor and document and maintain all correspondence

Ensure that all employees follow policies and procedures requiring Federal and State background investigations to be completed before staff begin working with children, provide relevant training to appropriate staff, and document and maintain documentation of all results.

Implement procedures and controls for collecting and reconciling information contained in its performance reports by developing protocols for collecting required data, handling system failures, and resolving discrepancies to ensure that all performance reports are accurate, verifiable, and reviewed before release to ORR.

Work with ORR to develop allowable methodologies to allocate salaries, develop a procedure or system to capture what programs each employee actually worked on, and determine what portion of the $1,500,218 in salaries charged based on budget estimates was accurately charged to the UAC program and refund to the Federal Government any unallowable portion

Work with ORR to determine an allocation methodology or plan to claim shared direct expenditures in proportion to benefits received, develop a policy to reflect this methodology or plan, determine whether any of the $1,352,027 in direct expenditures and up to $235,253 in related indirect expenditures allocated using the unreasonable allocation ratio was allowable, and refund to the Federal Government any unallowable portion

Develop policies and procedures for identifying allowable shared UAC program costs, including items that need advance approval, determine whether any of the $210,037 in potentially unallowable and $23,390 in potentially unallowable unapproved expenditures would be allowable under the newly approved allocation methodology or plan, and refund to the Federal Government any unallowable or unapproved portion

Develop policies and procedures for identifying shared UAC program costs not in compliance with Federal requirements and refund $10,336 in unallowable employee appreciation expenditures

Develop policies and procedures for identifying direct UAC program costs not in compliance with Federal requirements and refund $6,515 in unallowable expenditures not related to the UAC program

Develop policies and procedures for claiming indirect expenditures based on the approved indirect cost rate.

Assess, confirm, and recover the previously issued improper WHIP payments of $4,268,395 to program participants.

We recommend that the Executive Committee reconsider the need for all Railroad Retirement Board employees to have the mobile phone and the related recurring costs.

We recommend that the Executive Committee obtain state wage and unemployment data in a timelier manner in order to match with CARES Act Railroad Retirement Board payments; thereby identifying potential fraudulent CARES Act payments quicker and increasing program integrity.

In coordination with all EPA regions, ensure that guidance and planning address deployment of on-scene coordinators in the event of large incidents during pandemics, including overcoming travel restrictions to respond to large incidents.

Develop and implement a plan to coordinate relevant Agency program, regional, and administrative offices with the External Civil Rights Compliance Office to develop guidance on permitting and cumulative impacts related to Title VI.