Open Recommendations

(U) Rec. 3: The DoD OIG recommended that the Defense Commissary Agency Internal Review Office Chief update the Standard Operating Procedures to include policy for communicating the quality review results to appropriate personnel, in accordance with the 2018 revision of Government Auditing Standard 5.44.

(U) Rec. 5 (Letter of Comment): The DoD OIG recommended that the Defense Commissary Agency Internal Review Office Chief issue a memorandum reminding the auditors that they must document all discussions with management in the audit files.

(U) Rec. 6 (Letter of Comment): The DoD OIG recommended that the Defense Commissary Agency Internal Review Office Chief issue a memorandum reminding the auditors of the requirements in the Standard Operating Procedures for complying with quality control procedures, including the audit report checklist, the project quality control checklist, the independent reference review checklist, and the independent reference review certification.

(U) Rec. 7 (Letter of Comment): The DoD OIG recommended that the Defense Commissary Agency Internal Review Office Chief issue a memorandum reminding auditors of the requirements in Government Auditing Standard 9.14 and the Standard Operating Procedures for documenting the sampling methodology and design in the audit report.

(U) Rec. 8 (Letter of Comment): The DoD OIG recommended that the Defense Commissary Agency Internal Review Office Chief develop a tool, such as a checklist, to ensure the timely issuance of final reports in accordance with the Government Auditing Standards and the Standard Operating Procedures for the Defense Commissary Agency Internal Review Office.

(U) Rec. 9 (Letter of Comment): The DoD OIG recommended that the Defense Commissary Agency Internal Review Office Chief issue a memorandum reminding auditors of the importance of completing a statement of independence annually and including a copy of the statement in the audit file for each audit, in accordance with the Standard Operating Procedures for the Defense Commissary Agency Internal Review Office.

Remove or disable group accounts to comply with established requirements and criteria.

We recommend that CAS update its Review Guide to conform with applicable Federal regulations and CAS internal policies and procedures.

We recommend that CAS take steps to ensure that branch chiefs and negotiators follow all Federal and internal CAS requirements.

We recommend that CAS include all federally required documents on checklists provided to the nonprofit organizations and on checklists used by CAS officials.

We recommend that CAS review its staffing levels and determine whether resources are aligned efficiently, and adjust as needed, to ensure that the indirect cost rate-setting process is conducted in a timely manner.

We recommend that CAS seek clarification on whether the policy of including executive compensation higher than the Level II statutory cap in its indirect cost pool calculation complies with Federal law and governmentwide policy.

We recommend that CAS ensure that negotiated final indirect cost rates are calculated based on actual costs.

NIH should specifically require grantees to provide trainings and maintain a written policy regarding investigators' disclosure of other support.

NIH should modify reporting mechanisms to require grantees to report whether investigators' significant financial interests and other support involve foreign entities.

NIH should conduct outreach to grantees with R13 conference grants to clarify requirements regarding the disclosure and review of investigators' significant financial interests and other support.

We recommend that the Centers for Medicare & Medicaid Services instruct the DME MACs to recover $41,137 in overpayments for PMD repairs made to PMDs that belonged to 76 sampled beneficiaries.

We recommend that the Centers for Medicare & Medicaid Services instruct the DME MACs to based upon the results of this audit, notify appropriate suppliers (i.e., those for whom CMS determines this audit constitutes credible information of potential overpayments) so that the suppliers can 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 also recommend that the Centers for Medicare & Medicaid Services work with the DME MACs to do the following, which could have saved Medicare an estimated $7,948,182 during our audit period; Implement a system edit that applies to all PMD repairs and identifies PMD repairs for review of supplier documentation to help ensure that PMD repairs are adequately documented and that the PMD repair charges are reasonable and necessary.

We also recommend that the Centers for Medicare & Medicaid Services work with the DME MACs to do the following, which could have saved Medicare an estimated $7,948,182 during our audit period; Implement a system edit to determine whether PMD repair charges exceed the estimated cost to replace the PMDs being repaired.

We recommend that the Centers for Medicare & Medicaid Services establish Medicare requirements that: (1) include the documentation standards established by guidance for PMD repairs; (2) specify that accumulated costs of repairs made to power wheelchairs during their 5 year RUL must not exceed a certain threshold; and (3) specify that suppliers must provide warranties for repairs made to PMDs, which could have saved Medicare an estimated $3,739,346 during our audit period.

The FBI should clarify its policies regarding the approved methods for transmitting child sexual abuse material (CSAM) and other contraband to prosecutors and other government employees with a need to view the material in their official capacity.

Establish clearly defined and detailed roles, responsibilities, and processes for all SBA offices and officials responsible for managing and handling potentially fraudulent PPP loans to reduce the risk of ineligible applicants receiving PPP forgiveness and the risk of fraud and financial loss in the PPP and when implementing similar future programs.

Provide lenders formal guidance to effectively and consistently handle potentially fraudulent PPP loans and ensure lenders have sufficient guidance when implementing similar future programs.

Improve Agency systems to automate benefit computations and reduce the need for manual processing.