Open Recommendations

We recommend the Bureau of Indian Education develop and implement a review process to assess the status of all open work orders and make appropriate updates in the facility management system.

We recommend the Bureau of Indian Education, in coordination with Indian Affairs, develop and implement a continual monitoring process to assess the statuses of and close deferred maintenance work orders in the facility management system that have been addressed.

We recommend the Bureau of Indian Education, in coordination with Indian Affairs, ensure that every school has staff trained on managing work orders in the facility management system, including procedures for properly classifying, updating, and closing work orders.

We recommend that OPM's Contracting Officer require the PBM and Carrier to return $12,484,472 to the FEHBP for its portion of retail pharmacy pricing discounts not received from the PBM for CYs 2016 through 2021.

We recommend that OPM's Contracting Officer require the PBM and Carrier to return the FEHBP's portion of the PBM's "non-specific drug discounts" going back to the start of the Carrier's transparent agreement with the PBM, specifically for the period of CYs 2012 through 2015. The PBM has already identified an additional $1,397,520 in drug inventory purchasing discounts for CY 2015 that should be returned to the FEHBP as overcharges.

We recommend that OPM's Contracting Officer assess the PBM and Carrier $1,884,412 for LII on the questioned costs due back to the FEHBP for this finding, calculated through December 31, 2023. The LII should be adjusted to account for the date the questioned costs are returned to the program.

We recommend that OPM's Contracting Officer require the Carrier to adopt new controls to ensure that the PBM charges no greater than the value of the PBM's negotiated discounts with each retail pharmacy in effect at the time of claim adjudication. True-ups to any retail pricing guarantees should be performed quarterly or annually in accordance with the Carrier's PBM agreement.

We recommend that OPM's Contracting Officer require the PBM and Carrier to return $5,911,973 to the FEHBP for its portion of the PBM's non-specific drug inventory purchasing discounts that were not received for CYs 2016 through 2021.

We recommend that OPM's Contracting Officer assess the PBM and Carrier $911,290 for LII on the questioned costs due back to the FEHBP for this finding, calculated through December 31, 2023. The LII should be adjusted to account for the date the questioned costs are returned to the program.

We recommend that the Carrier adopt new controls to ensure that the PBM passes through all its drug inventory purchasing discounts associated with the Carrier and FEHBP in accordance with the PBM Transparency Standards for mail order and specialty drug actual acquisition costs.

We recommend that Carrier collect $2,279,264 in claim transaction fees that were credited back to the PBM by retail pharmacies for the Carrier's CY 2016 through 2021 prescription drug benefits.

We recommend that OPM's Contracting Officer assess the PBM and Carrier $289,501 for LII on the questioned costs due back to the FEHBP for this finding, calculated through December 31, 2023. The LII should be adjusted to account for the date the questioned costs are returned to the program.

We recommend that the PBM adopt policies and procedures to ensure that the Carrier receives the value of all credits (i.e., claim transaction fees) that the PBM collects from retail pharmacies under pass-through transparent pricing.

We recommend that OPM's Contracting Officer assess the PBM and Carrier $374,636 for LII on the questioned costs due back to the FEHBP for this finding, calculated through December 31, 2023. The LII should be adjusted to account for the date the questioned costs are returned to the program.

We recommend that the PBM adopt controls to ensure that all drug manufacturer rebates are properly allocated and passed through to the FEHBP.

We recommend that FWS require the Department to implement controls that include maintaining records sufficient to determine the accurate impact of any future labor mischarging.

We recommend that the Secretary for the U.S. Department of the Interior or a designee coordinate with the U.S. Department of Agriculture to assign responsibility for the required annual report and ensure that each annual report is completed and that all components required in the report are addressed after the publication of the performance metric mentioned in Recommendation 2, as established in IIJASection 40206(f), "Annual Reports."

Develop a standard operating procedure for the monthly transaction review that aligns with the HUD policy and includes specific procedures on how to (1) identify and review common transactions that raise the level of risk in the program (for example, personal use purchases, other prohibited purchases, unauthorized purchases or services, split purchases, fraudulent purchases, FAR violation purchases, etc.), (2) methodically select transactions for investigation, and (3) follow up on identified potential improper transactions, including record-keeping requirements.

Develop and fully implement a departmentwide policy for the monthly transaction review process that requires program office participation and timely completion of the review and certification.

Implement a baseline of technologies that sustain and do not erode privacy protectionsrelating to the use, collection, and disclosure of information.

Implement the EDR tool that was previously acquired for privacy protection.

Identify and implement other technologies that will bring the FCC into fullcompliance with the requirement for continuous auditing of compliance with statedprivacy policies and practices.

Document a formal process to perform PIAs for proposed rules, including details on thetype of personally identifiable information collected and the number of people affected, inthe FCC Privacy Act Manual, as a requirement.

Update its business case for the MySBA investment in accordance with SOP 90 44 SBA Information Technology and Capital Planning and Investment Control Standard Operating Procedures.

Ensure the architecture review board reviews new investments to confirm compatibility with agency systems and ensure the Business Technology Investment Council approves new investments prior to purchase, as required by SOPs 90 52 1 and 90 44.