Open Recommendations

We recommend that the Colorado Department of Health Care Policy and Financing work with CMS to determine the total amount of claims that were eligible for rebates as well as the unallowable portion of the physician-administered drug claims, invoice drug manufacturers for the calculated rebates, and refund the Federal share of rebates collected for the years covered by our audit period and for years after our audit period.

We recommend that the Colorado Department of Health Care Policy and Financing develop and implement policies and procedures to ensure that all eligible physician-administered drugs, including those dispensed to MCO enrollees, are invoiced for rebate.

Develop and institute an agency-wide process to prioritize and fund institutional and programmatic CoF projects that align with Agency-level missions and goals and require business case analyses to be completed and considered as part of the process prior to the project's approval.

In coordination with the Mission Directorates, institute a process to ensure facility requirements are identified and funding sources are specified during a program’s development and implementation phases.

Develop a strategy to work with Federal agencies to reduce the eligible disposal backlog.

Review policies and procedures and determine which internal stakeholders, including the IG, should be notified and revise policies and procedures as necessary.

Prioritize creation of DEER and DCR Audit Reports under the ARCIS contract.

Develop a strategy to transition agencies to use the ARCIS Customer Portal Disposition Module.

Develop and implement an ARCIS internal user manual.

The Bureau of Consular Affairs should implement a process to store the Passport Services Directorate’s archived advisory opinions, so they are easily searchable and retrievable in accordance with Department standards.

Take steps to ensure that all convictions and adverse actions are reported to Federal partners within the appropriate timeframes

Revise the Unit's MOU with the State Medicaid agency to establish procedures by which the Unit will receive referrals of potential fraud from managed care organizations

The Bureau of Fiscal Operations should develop and maintain comprehensive set of policies and procedures for the Debt Recovery Section, Financial Systems Section, and Treasury Section, using in-house personnel with adequate relevant expertise and experience, or outsource the task to an entity with the relevant expertise and experience.

The Bureau of Fiscal Operations should assess the work effort required and hire adequate personnel to perform Financial Systems Section functions.

The Bureau of Fiscal Operations should ensure that the development and maintenance of policies and procedures for the Debt Recovery Section, Financial Systems Section, and Treasury Section are performed by personnel with appropriate expertise.

The Bureau of Fiscal Operations should maintain documentary evidence of adequate periodic review of control activities performed.

The Bureau of Fiscal Operations should ensure that the Debt Recovery Section’s policies and procedures include guidance and process for developing and modifying thresholds, including those related to waivers and write-offs.

The Bureau of Fiscal Operations should maintain documentary evidence of adequate supervisory review of control activities around recording of transactions and reconciliations for the Debt Recovery Section.

The Bureau of Fiscal Operations should develop and maintain a comprehensive set of policies and procedures for outsourcing the Financial Systems Section functions.

The Bureau of Fiscal Operations should develop an oversight framework for overseeing the Financial Systems Section’s contractors, and ensure that the framework is reviewed and updated periodically.

The Bureau of Fiscal Operations should require Service Level Agreements or equivalent documentation that clearly defines the roles and responsibilities of the Railroad Retirement Board and Conseillers en gestion et informatique (a shared service provider within the federal industry) and ensure that the documentation is reviewed and updated periodically.

The Bureau of Fiscal Operations should perform an assessment to determine adequate staffing required to perform Financial System Service’s functions.

The Bureau of Fiscal Operations should hire adequate personnel to perform its functions.

The Bureau of Fiscal Operations should develop a written succession plan for the Financial Systems Section, including a framework for ensuring that human capital risk is assessed, to address key person dependency risk, including training personnel and documenting processes and procedures defining the scope of responsibilities required for achieving the section’s objectives.

The Bureau of Fiscal Operations should develop and implement policies and procedures requiring the periodic review of the Cost Accounting Code by Individual data, to assess the reasonableness of personnel roles and responsibilities, resources expended (hours and amounts), and resulting deliverables or output.