Open Recommendations

We recommend the Under Secretary, Office of Strategy, Policy, and Plans, in consultation with the Under Secretary of Management, coordinate with DOJ and State to develop an agreement that facilitates the direct sharing of passport information within the JTTF environment through State's formal MOU process.

We recommend the Under Secretary of Management coordinate with the Information Sharing and Safeguarding Governance Board to ensure: - ICE and TSA develop an agreement for TSA to directly process Secure Flight data requested for use by JTTF or HSI JTTF agents investigating terrorism activities or performing task force specific missions, and - DHS JTTF contributors mitigate data restrictions or delays pertaining to law enforcement and intelligence investigations.

Evaluate the EPA’s Intergovernmental Personnel Act Policy and Procedures Manual (IPA), including the checklist, to determine whether the required documents, the consequences for noncompliance, the responsible offices, and the individual roles and responsibilities remainrelevant and appropriate, and update the Manual accordingly.

Strengthen controls throughout the EPA’s Intergovernmental Personnel Act assignment process to verify that required documents are properly submitted and maintained as required by the EPA’s Intergovernmental Personnel Act Policy and Procedures Manual (IPA) and that theconsequence for nonsubmittal of required documents is enforced.

We recommend that Condado Home Care Program, Inc., for the remaining portion of the estimated $97,210 in overpayments that are outside of the Medicare reopening period, exercise reasonable diligence to identify and return overpayments in accordance with the 60-day rule and identify any returned overpayments as having been made in accordance with this recommendation.

We recommend that Condado Home Care Program, Inc., based upon 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.

We recommend that Condado Home Care Program, Inc. strengthen its procedures to ensure that: - the homebound status of Medicare beneficiaries are verified and continually monitored and the specific factors qualifying beneficiaries as homebound are documented; - beneficiaries are receiving only reasonable and necessary skilled services; - home health episodes are billed correctly; and - plans of care comply with Medicare requirements.

We recommend that Condado Home Care Program, Inc. refund to the Medicare program the portion of the estimated $97,210 in overpayments for claims incorrectly billed that are within the 4-year claim reopening period.

We recommend that Visionquest Industries, Inc.: refund to the DME MACs the portion of the $2,504,829 in estimated overpayments for claims that are within the 4-year reopening period.

We recommend that Visionquest Industries, Inc.: exercise reasonable diligence to identify and return any additional similar overpayments in accordance with the 60-day rule,20 and identify any of those returned overpayments as having been made in accordance with this recommendation

Rec. 1: The DoD OIG recommended that the Assistant Secretary of Defense for Health Affairs update Memorandum, "TRICARE Policy for Access to Care," February 23, 2011, to remove the eight-visit limitation for outpatient mental health care.

Rec. 2.a: The DoD OIG recommended that the Defense Health Agency Director develop a single Military Health System-wide staffing approach for the Behavioral Health System of Care that estimates the number of appointments and personnel required to meet the enrolled population's demand for mental health services.

Rec. 2.c.1: The DoD OIG recommended that the Defense Health Agency Director update and clarify DoD and Defense Health Agency policy, including TRICARE policy to update the access to care standard for a non?urgent initial behavioral health assessment in Defense Health Agency and TRICARE policy to be consistent with the 7?day standard established by the Assistant Secretary of Defense for Health Affairs Memorandum, TRICARE Policy for Access to Care, dated February 23, 2011.

Rec. 2.c.2: The DoD OIG recommended that the Defense Health Agency Director update and clarify DoD and Defense Health Agency policy, including TRICARE policy to develop a standard definition and required elements for an initial non?urgent mental health assessment and develop a way to track whether the assessment is completed within the 7?day standard, in either a primary care or a specialty mental health clinic.

Rec. 2.c.3: The DoD OIG recommended that the Defense Health Agency Director update and clarify DoD and Defense Health Agency policy, including TRICARE policy to describe standard procedures for implementing centralized appointing for behavioral health services.

Rec. 2.c.4: The DoD OIG recommended that the Defense Health Agency Director update and clarify DoD and Defense Health Agency policy, including TRICARE policy to standardize the outpatient mental health care process of providing behavioral health services from first patient contact through follow?up care for a patient needing non?urgent outpatient mental health care.

Rec. 2.f.1: The DoD OIG recommended that the Defense Health Agency Director develop standardized mental health access to care measures for direct and purchased care for both active duty service members and their families, to include tracking the time from patient request or referral for mental health care to the time of the initial non?urgent mental health assessment.

Rec. 2.f.4: The DoD OIG recommended that the Defense Health Agency Director develop standardized mental health access to care measures for direct and purchased care for both active duty service members and their families, to include tracking reasons patients are unable to book an appointment.

The Assistant Secretary for Employment and Training should issue guidance directing states to provide access to state UI claimant data, in order to prevent and detect fraud.

We recommend that Desoto Home Health Care, Inc. based upon the results of this audit, exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule14 and identify any of those returned overpayments as having been made in accordance with this recommendation.

We recommend that Desoto Home Health Care, Inc. obtain as much information from beneficiary medical records as it determines necessary to assure itself that claims for orthotic braces meet Medicare requirements for medical necessity.

CMS should seek legislative authority to establish a mechanism to control costs for automated chemistry tests

We recommended that CMS direct its Medicare contractors to reprocess the remaining inpatient claims identified in our sample frame with an incorrect patient discharge status code when beneficiaries resumed home health services within 3 days of discharge and recover the portion of the estimated $218,538,919 in overpayments that are within the 4-year reopening period along with similarly coded inpatient claims after our audit period.

We recommended that CMS use data analytics to identify hospitals that disproportionately use condition code 42 when the diagnosis codes on the inpatient claim and the respective home health claim appear related.

We recommended that CMS direct its Medicare contractors to analyze the remaining inpatient claims in our sample frame with a condition code 42, determine which claims were overpaid, and recover the portion of the estimated $40,610,333 in potential overpayments that are within the 4-year reopening period along with similarly coded inpatient claims paid after our audit period.