Open Recommendations

Develop and implement a written process to ensure manual updates to the CMDB inventory and FasseTrack system are made simultaneously when the inventory is updated.

Develop and implement a written process to perform periodic reconciliations between CMDB and the FasseTrack system.

Perform and document analysis to determine the feasibility of completely automating the inventory management process.

Physically or mechanically disable the networking capability of the laptop used for member badging at the NCCC Pacific Region Campus.

Document and implement a process to validate that physical counselor files from the NCCC Southwest Region Campus are disposed of within six years after the date of the member’s graduation in accordance with the AmeriCorps NCCC Manual.

Replacement of information system components when support for the components is no longer available from the developer, vendor or manufacturer.

Enhance the inventory process to ensure all devices are properly identified and monitored.

Federal regulations define rehabilitative services as services recommended by a licensed practitioner for maximum reduction of physical or mental disability and restoration of a beneficiary to their best possible functional level. State regulations for PACT, which the State agency defines in its Medicaid State plan as a rehabilitative program, stipulate that the prior authorization of services shall cover all dates that services were provided to ensure proper reimbursement. Although State regulations stipulate that a prior authorization should cover all dates of service, they do not specify a timeframe for which authorized services are eligible for Medicaid reimbursement. Essentially, this results…

Of the 100 sampled State agency claims for Federal Medicaid reimbursement of payments for PACT services, 50 complied with Federal and State requirements, but the remaining 50 did not. The below deficiencies were found and many of the claims had more than one deficiency. *Services not adequately supported or documented *Plan of care requirements not met *Required clinical disciplines not included on PACT team *Prior authorization requirements not met *No documentation of compliance with boarding home requirements *Documentation did not support 2 hours of face-to-face contact *No nursing assessment

Of the 100 sampled State agency claims for Federal Medicaid reimbursement of payments for PACT services, 50 complied with Federal and State requirements, but the remaining 50 did not. The deficiencies occurred because the State agency did not inform PACT providers of all Federal and State requirements for providing PACT services, and its monitoring procedures were not adequate to identify all instances when providers did not claim PACT services in accordance with these requirements. In fact, the monitoring procedures did not include checking whether some requirements were met. As a result, PACT providers did not follow requirements for providing PACT…

Of the 100 sampled, State agency claims for Federal Medicaid reimbursement of payments for PACT services, 50 complied with Federal and State requirements, but the remaining 50 did not. These deficiencies occurred because providers were not aware of all PACT requirements or did not adhere to the requirements.

Review IRDF’s use of prolonged administrative segregation and seek alternative housing when appropriate.

Ensure that, for detainees in administrative segregation, IRDF provides outdoor recreation and access to privileges similar to those offered to detainees in the general population, in compliance with 2011 PBNDS requirements.

Require IRDF staff to complete daily face-to-face medical visits with detainees in administrative segregation to ensure detainee welfare.

Review the IRDF facility conditions we identified as deficient to ensure corrective action in compliance with 2011 PBNDS requirements.

Require IRDF staff to provide written responses to medical grievances and provide copies to the detainees who filed the grievances.

More clearly identify time, duration, and location for facility visits to ensure detainees’ regular access to assigned ICE ERO deportation officers.

We recommend that the Centers for Medicare & Medicaid Services instruct the Medicare contractors to review the $2,263,465 in improper payments for claims with dates of service after the beneficiaries’ dates of death and initiate recoupment for the amounts identified as improper payments.

We recommend that the Centers for Medicare & Medicaid Services instruct the Medicare contractors to review deductible amounts that may have been incorrectly collected from beneficiaries or from someone on their behalf and take appropriate actions to resolve these amounts.

We recommend that Novitas Solutions, Inc. educate providers on how to correctly calculate the prorated mileage for phlebotomy travel allowance payments.

We recommend that Novitas Solutions, Inc. educate providers on their responsibility to bring any previously paid claims to their MAC's attention if they were paid using the wrong rate.

We recommend that Novitas Solutions, Inc. educate providers on their responsibility to maintain adequate documentation to support payment for phlebotomy travel allowance payments.

We recommend that Novitas Solutions, Inc. work with the Centers for Medicare & Medicaid Services to clarify guidance to providers, which could have resulted in savings totaling an estimated $2,373,676 during our audit period.

We recommend that the New York Department of Health refund $614,530 to the Federal Government.

Rec. 1.a: The DoD OIG recommended that the Defense Health Agency Director continue to monitor morphine milligrams equivalent per day by beneficiary, examine data for unusually high opioid prescriptions, and if appropriate, hold providers accountable for overprescribing opioids.