Open Recommendations

We recommend that Partners In Care, Inc. based upon the results of this audit, 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 recommend that Partners In Care, Inc. strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend the Federal Emergency Management Agency Administrator address unresolved implementation issues, publish proposed regulations for notice and comment within 1 year, and issue final regulations within 3 years of issuance of this report for implementation of the Disaster Mitigation Act of 2000, 42 U.S.C. § 5172(b)(2).

We recommend the Federal Emergency Management Agency Administrator review and resolve hazard mitigation challenges, such as: 1. ensuring education and training of states and applicants on mitigationprograms and availability of funding at the state and applicant levels;2. revising criteria and instructions for completing benefit-cost analyses toclarify and streamline the process and assist applicants with meeting therequired benefit-cost threshold;3. streamlining the processes from application submission to approval todecrease applicants’ wait time for mitigation; and4. considering existing flexibilities to adjust the cost share for applicantsexperiencing financial hardships.

Update Agency guidance on practical enforceability to more clearly describe how the technical accuracy of a permit limit should be supported and documented. In updating such guidance, the Office of Air and Radiation should consult and collaborate with the Office of Enforcement and Compliance Assurance, the Office of General Counsel, and the EPA regions.

In consultation with the EPA regions, develop and implement an oversight plan to include: (a) an initial review of a sample of synthetic-minor-source permits in different industries that are issued by state, local, and tribal agencies to assess whether the permits adhere to EPA guidance on practical enforceability, including limits that are technically accurate, have appropriate time periods, and include sufficient monitoring, record-keeping, and reporting requirements; (b) a periodic review of a sample of synthetic- minor-source permits to occur, at a minimum, once every five years; and (c)procedures to resolve any permitting deficiencies identified during the initial and periodic reviews.

Assess recent EPA studies of enclosed combustion device performance and compliance monitoring and other relevant information during the next statutorily required review of 40 C.F.R Part 60 Subparts OOOO and OOOOa to determine whether revisions are needed to monitoring, record-keeping, and reporting requirements for enclosed combustion devices to assure continuous compliance with associatedlimits, and revise the regulatory requirements as appropriate.

Revise the Agency’s guidance to communicate its key expectations for synthetic-minor-source permitting to state and local agencies.

Identify all state, local, and tribal agencies in which Clean Air Act permit program implementation fails to adhere to the public participation requirements for synthetic-minor-source permit issuance and take appropriate steps to assure the identified states adhere to the public participation requirements.

We recommend that Mission Hospice & Home Care, Inc.: refund to the Federal Government the portion of the estimated $10,564,396 for hospice services that did not comply with Medicare requirements and that are within the 4-year reopening period.

We recommend that Mission Hospice & Home Care, Inc.: strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services, as part of its ERM program, implement a process to assess all of its programs for national security risks in accordance with OMB Circular No. A-123's requirement to include new or emerging risks in the risk profile.

We recommend the Associate Administrator, FEMA Office of Response and Recovery ensure its direct housing information system provides flexibility implementing alternative direct housing options; provides support to states, territories, and tribal governments administering direct housing assistance; and facilitates data exchange and sharing with non-FEMA information systems.

We recommend that Puerto Rico Department of Health revise its EOP, including adding or updating procedures, to comply with HPP-PHEP Cooperative Agreement requirements related to: (1) conducting annual public health and medical preparedness exercises or drills that include at-risk populations in all of its planning and activities; (2) identifying resources for at-risk populations; (3) anticipating storage needs for a surge of human remains; (4) implementing and identifying emergency procurement procedures; (5) clearly defining HCC Specialists' responsibilities; (6) obtaining public comment and input on its EOP; (7) utilizing EMAC or other public health mutual aid agreements to support coordinated activities when…

We recommend that the Puerto Rico Department of Health consider working with ASPR to develop an effective method for contacting healthcare volunteers when there are communication challenges.

We recommend that Puerto Rico Department of Health consider coordinating with appropriate organizations to develop guidance on accurate cause-of-death certifications focusing on whether underlying causes of death were disaster-related.

We recommend that the New York State Department of Health (State agency) refund $6,027,566 to the Federal Government.

Based on the results of this audit, we recommend that the Centers for Medicare & Medicaid Services notify appropriate providers (i.e., those for whom CMS determines that this audit constitutes credible information of potential overpayments) so that the providers 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.

Based on the results of this audit, we recommend that the Centers for Medicare & Medicaid Services implement claims processing controls, including system edits, to prevent and detect overpayments for TCM.

The Bureau of Information Resource Management should review and update the Enterprise IT Help Desk and Desktop Support Master Service Level Agreement to align with the current Bureau of Information Resource Management service catalog.

The Bureau of Information Resource Management should define out-of-scope services in the Enterprise IT Help Desk and Desktop Support Master Service Level Agreement.

The Bureau of Information Resource Management should update the Enterprise IT Help Desk and Desktop Support Master Service Level Agreement to include the methodology for calculating the incident resolution time.

The Bureau of Information Resource Management should update the Enterprise IT Help Desk and Desktop Support Master Service Level Agreement to reflect the current technology modernization policy.

The Bureau of Information Resource Management should review its technology modernization purchasing policies and determine if the Enterprise IT Help Desk and Desktop Support Master Service Level Agreement requires updates to these policies based on its review.

The Bureau of Information Resource Management, in coordination with the Bureau of Administration should, upon completion of the comprehensive cost model study, adjust the Office of Consolidated Customer Support’s desktop service fee, if necessary, and publish a pricing schedule for all customers.