Open Recommendations

The Veterans Integrated Service Network Chief Medical Officer oversees the healthcare system’s privileging processes.

The Chief of Staff ensures designated staff complete the Comprehensive Suicide Risk Evaluation the same calendar day, when logistically feasible and clinically appropriate, for all ambulatory care patients with a positive suicide risk screen.

The Chief of Staff ensures clinical staff notify the suicide prevention team when patients report suicidal behaviors during the Comprehensive Suicide Risk Evaluation.

The Office of Programs should create a cover sheet with a checklist that allows the Contracting Officer’s Representative to verify that the following requirements have been met: The claims examiner signed and dated form G-137 SUP, via a written/electronic signature or a “sticky note;” and Current medical evidence is included in each medical opinion.

The Office of Programs should work with the RRB’s Executive Committee to determine which RRB employees should be provided annual training regarding the review and acceptance of medical opinions to ensure RRB’s internal controls for the usage of medical opinions in the disability determination process are designed and operating effectively.

The Office of Programs should require a secondary authorizer to review each medical opinion.

The Office of Programs should create controls that require the Contracting Officer’s Representative to sample medical opinions and review them for acceptability on a routine basis.

The Office of Programs should retrain the examiners to sign each medical opinion they review and ensure that current medical evidence is included.

The Office of Programs should work with the RRB’s Executive Committee to retrain applicable employees regarding the medical opinion approval process and document retention requirements to ensure the evaluation of medical opinions follows RRB’s internal controls.

The Office of Programs should review the 11 incomplete medical opinions to determine if the missing information from the medical opinion would change the disability determination and expand the review of medical opinions if disability determinations are found to be impacted.

The Office of Programs should work with Office of Administration to determine if additional Contracting Officer’s Representatives are required to ensure proper contractual and technical oversight and monitoring of the medical opinions contract.

The Office of Programs should work with Office of Administration to revise the approval process in the Disability Claims Manual so that claims examiners do not approve payment for medical opinions and develop a new process for the Contracting Officer’s Representative or the Alternate Contracting Officer’s Representatives to review and approve payment for medical opinions.

The Office of Programs should work with Acquisition Management to include language in the next medical services contract requiring that if consultation sessions with the consultants occur online, payments are in 30-minute increments in which consultation occurs, instead of the entire 4-hour window.

The Office of Programs should work with Acquisition Management to modify the language in Contract 1, dated December 1, 2020, to require that the medical services contractor submit medical licenses, insurance, and annual training certifications on an annual basis.

The Office of Programs should develop an internal control, replacing internal control number 14-3 from the Office of Administration’s Chart of Controls in the Disability Benefits Division’s Chart of Controls, to ensure that the medical licenses, insurance, and annual training certifications are reviewed on a timely basis.

The Office of Programs should develop additional controls to ensure that the medical services contractor regularly submits the six required timeliness reports in accordance with their contract requirements.

Continue to provide training and collaborate with program office staff to ensure the timely and complete reconciliation of the population of transactions used for estimating improper payments to the general ledger is performed, as needed.

Proactively seek and obtain guidance from OMB in the first year of a new program’s implementation and develop a plan to ensure compliance with PIIA reporting requirements, as needed.

Enhance existing procedures using the framework in the Government Accountability Office’s Green Book to design and implement robust internal and quality control processes to ensure complete and accurate reporting of annual improper payment results and formalized risk assessment processes to ensure all programs and activities are considered sufficiently to meet PIIA reporting objectives.

Design and implement enforceable actions and controls to hold lenders accountable for not providing all documentation requested for loan samples in a timely manner.

Formally document and implement additional preventative and monitoring controls to determine the eligibility of loans prior to loan approval and payments and loan guaranty purchases.

Collaborate with the responsible staff involved in the payment integrity reporting process to ensure timely and complete reconciliations are performed on the populations subject to sampling for improper payment reviews.

Exercise effective management review controls over the statistician’s work product by verifying that the documentation of the sampling and estimation methodology plans comprehensively outlines the details of the implemented sampling and extrapolation methodology, while maintaining statistical validity.

Design and implement effective communication and review processes with responsible staff involved in the payment integrity reporting process to ensure compliance for the reporting of new programs and activities.

Design and document adequate review procedures to ensure that the results of the sample meet the PIIA objectives.