Open Recommendations

We recommend that Staten Island University Hospital refund to the Medicare contractor the portion of the $11,761,274 in estimated overpayments for the audit period for claims that it incorrectly billed that are within the 4-year reopening period.

We recommend that the Centers for Medicare & Medicaid Services make regulatory changes to allow it to require accreditation organizations to perform special surveys of hospitals selected by CMS after it issues new substantive participation requirements or guidance that it determines warrant additional validation to ensure timely compliance.

We recommend that the Centers for Medicare & Medicaid Services make regulatory changes to allow it to require accreditation organizations to perform special surveys of hospitals selected by CMS during a public health emergency to address the risks presented by the emergency.

We recommended that the Kentucky Department for Medicaid Services refund $29,431,268 to the Federal Government.

We recommended that the Kentucky Department for Medicaid Services amend its CAP to address the statistical validity issues we identified.

We recommended that the Kentucky Department for Medicaid Services enhance RMS procedures to ensure that its RMTS methodology complies with Federal requirements for statistical validity.

We recommended that the Kentucky Department for Medicaid Services enhance RMS procedures to ensure that its Medicaid administrative cost claim complies with Federal requirements for allocable costs.

We recommended that the Kentucky Department for Medicaid Services enhance policies and procedures to ensure that changes to its RMTS methodology are incorporated into a CAP amendment and promptly submitted to DCA for review.

We recommended that the Kentucky Department for Medicaid Services review school-based Medicaid administrative costs claimed after our audit period and refund any unallowable amounts.

Require the Puerto Rico DOE to demonstrate that it has implemented sufficient controls over its payroll system to ensure that Department program funds are safeguarded; and, if it cannot, impose specific conditions on all Department grants awarded, including disaster and pandemic relief grants prohibiting the use of grant funds for payroll without documentation to support that payments went to active employees.

Closely monitor the Puerto Rico DOE’s implementation of internal controls over payroll included in its corrective action plan prepared in response to the new time and attendance controls required by the Puerto Rico Financial Oversight and Management Board.

Require the Puerto Rico DOE to identify the amount of unallowable payroll costs charged to the Emergency Impact Aid program and other Department program funds and establish a plan to return those funds to the Department.

We recommend that Northwest Hospice, LLC refund to the Federal Government the portion of the estimated $3,902,337 for hospice services that did not comply with Medicare requirements and that are within the 4-yearreopening period.

We recommend that NW Hospice, LLC 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 Northwest Hospice, LLC strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

OIG recommends that the Under Secretary for Management verify periodically, but no less than quarterly, that those entities with recommendations that have yet to be implemented and closed are providing status updates and responses to OIG in a timely manner, as required.

CMS should identify and implement an appropriate way to address cybersecurity of networked medical devices in its quality oversight of hospitals, in consultation with HHS partners and others.

Rec. 3.a: The DoD OIG recommended that the Vice Chief of Staff of the Army; Vice Chief of Naval Operations; and the Vice Chief of Staff of the Air Force, in coordination with the Assistant Commandant of the Marine Corps and the Assistant Secretary of Defense for Sustainment establish clear order of precedence between the memorandum of agreement, joint base policy, and Service policies for joint bases.

Rec. 3.a: The DoD OIG recommended that the Vice Chief of Staff of the Army; Vice Chief of Naval Operations; and the Vice Chief of Staff of the Air Force, in coordination with the Assistant Commandant of the Marine Corps and the Assistant Secretary of Defense for Sustainment establish clear order of precedence between the memorandum of agreement, joint base policy, and Service policies for joint bases.

Rec. 3.b: The DoD OIG recommended that the Vice Chief of Staff of the Army; Vice Chief of Naval Operations; and the Vice Chief of Staff of the Air Force, in coordination with the Assistant Commandant of the Marine Corps and the Assistant Secretary of Defense for Sustainment develop internal procedures to ensure joint base needs are considered in Service-specific processes and decisions.

Rec. 3.c: The DoD OIG recommended that the Vice Chief of Staff of the Army; Vice Chief of Naval Operations; and the Vice Chief of Staff of the Air Force, in coordination with the Assistant Commandant of the Marine Corps and the Assistant Secretary of Defense for Sustainment develop collaborative processes between the Services to identify and implement best practices at joint bases.

Rec. 3.d: The DoD OIG recommended that the Vice Chief of Staff of the Army; Vice Chief of Naval Operations; and the Vice Chief of Staff of the Air Force, in coordination with the Assistant Commandant of the Marine Corps and the Assistant Secretary of Defense for Sustainment conduct a review of all joint bases, to include the memorandum of agreement to identify potential command authority and organizational conflicts, and assess the effectiveness of support systems to joint bases.

Rec. 3.d: The DoD OIG recommended that the Vice Chief of Staff of the Army; Vice Chief of Naval Operations; and the Vice Chief of Staff of the Air Force, in coordination with the Assistant Commandant of the Marine Corps and the Assistant Secretary of Defense for Sustainment conduct a review of all joint bases, to include the memorandum of agreement to identify potential command authority and organizational conflicts, and assess the effectiveness of support systems to joint bases.

Rec. 3.e: The DoD OIG recommended that the Vice Chief of Staff of the Army; Vice Chief of Naval Operations; and the Vice Chief of Staff of the Air Force, in coordination with the Assistant Commandant of the Marine Corps and the Assistant Secretary of Defense for Sustainment establish training or direct joint base commanders to issue local guidance to ensure installation personnel comply with established processes to update the memorandum of agreement and implement its current provisions.

Rec. 4.c: The DoD OIG recommended that the Assistant Secretary of Defense for Sustainment issue updated guidance to clarify when Service decisions directly impact a joint base and the support provided by the lead Component should be documented in the memorandum of agreement, and what actions require concurrence from the Joint Management Oversight Structure.