Open Recommendations

We recommend that CMS based on the results of this audit, notify appropriate physicians (i.e., those for whom CMS determines that this audit constitutes credible information of potential overpayments) so that the physicians 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 recommend that CMS • implement improved claims processing controls, including improved system edits, to prevent and detect overpayments of claims for duplicate services.

We recommend that Anthem Community Insurance Company, Inc. refund to the Federal Government the $3,468,954 of net overpayments.

We recommend that Anthem Community Insurance Company, Inc. identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before or after our audit period and refund any resulting overpayments to the Federal Government.

We recommend that Anthem Community Insurance Company, Inc. enhance its compliance procedures to focus on diagnosis codes that are at high risk for being miscoded by determining whether these diagnosis codes (when submitted to CMS for use in CMS’s risk adjustment program) comply with Federal requirements and educating its providers about the proper use of these diagnosis codes.

Rec. 1.c: The DoD OIG recommended that the Under Secretary of Defense for Research and Engineering and the Under Secretary of Defense for Acquisition and Sustainment revise DoD Instruction 5000.85 and its supplementary acquisition policy issuances to require program managers of major defense acquisition programs to use scientific test and analysis techniques to the maximum extent possible to develop the Test and Evaluation Master Plan.

Rec. 1.f: The DoD OIG recommended that the Under Secretary of Defense for Research and Engineering and the Under Secretary of Defense for Acquisition and Sustainment revise DoD Instruction 5000.85 and its supplementary acquisition policy issuances to require program managers of major defense acquisition programs to include the most critical or stressing test conditions in revised test plans when proposing elimination, deferral, or modification of planned tests that were originally documented in the Test and Evaluation Master Plan.

Require the Chicago PD to perform an in-depth review of its equitable sharing financial
activity and either: (1) provide detailed documentation to support its existing FY 2019 and
FY 2020 ESAC submissions, or (2) submit amended ESACs along with detailed documentation
to support the balance and expenditure figures reported.

We recommend that Sleep Management refund to the Federal Government the portion of the estimated $29,131,187 in Medicare overpayments for claim lines incorrectly billed that are within the 4-year reopening period.

We recommend that Sleep Management follow existing policies and procedures to help ensure that it: (1) obtains medical record documentation that is sufficient to satisfy Medicare medical necessity requirements and (2) discontinues service when beneficiaries do not continually use the device.

Establish and operate monitoring activities, including ongoing monitoring, separate evaluations, or a combination of the two to obtain reasonable assurance of the operating effectiveness of FSA’s verification control activities

Establish processes to ensure that FSA management evaluates and documents corrective actions, including when corrective actions are not taken, for verification control weaknesses identified by monitoring activities.

For issues identified with its verification control activities in the 2018 ERM Report and other monitoring activities, ensure that FSA management evaluates and documents corrective actions, or if corrective actions are not warranted.

Conduct periodic reviews of the level of basic essential air service in accordance with Federal regulations.

We recommend that the New York State Office of Temporary and Disability Assistance work with its local districts and TANF-funded State programs to develop financial management procedures that would enable the State agency to determine if TANF and MOE expenditures are accurately reported to ACF, including the $4.8 billion in TANF and MOE expenditures reported for FY 2016.

We recommend that the New York State Office of Temporary and Disability Assistance improve its oversight of the TANF program by providing additional guidance and training to ensure that its local districts accurately report expenditures and maintain adequate documentation to support TANF and MOE expenditures reported.

We recommend that Franciscan: Refund to the Federal Government the portion of the estimated $13,027,841 for hospice services that did not comply with Medicare requirements and that are within the 4-year reopening period.

We recommend that Franciscan: strengthen its policies and procedures to ensure that hospice services comply with Medicare requirements.

(U) Rec. 6.a: The DoD OIG recommended that the Under Secretary of Defense for Acquisition and Sustainment, in conjunction with the Under Secretary of Defense for Policy and U.S. Special Operations Command, develop a plan of action and milestones to establish policies related to the capability of United States defense contractors to meet DoD Counter Threat Finance mission needs.

(U) Rec. 6.b: The DoD OIG recommended that the Under Secretary of Defense for Acquisition and Sustainment, in conjunction with the Under Secretary of Defense for Policy and U.S. Special Operations Command, develop a plan of action and milestones to coordinate with the Under Secretary of Defense for Intelligence on innovative uses of technology to address intelligence-related Counter Threat Finance issues.

(U) Rec. 7: The DoD OIG recommended that the Under Secretary of Defense for Policy, in conjunction with U.S. Special Operations Command, develop a plan of action and milestones to implement the Counter Threat Finance Department of Defense Instruction as outlined in the approved Doctrine, Organization, Training, Materiel, Leadership, Personnel, Facilities, and Policy Change recommendation, which includes: 1. Developing a common lexicon for Counter Threat Finance. 2. Establishing procedures for nominating targets for sanctions and designations. 3. Establishing procedures for coordinating and executing Counter Threat Finance activities across organizational and geographic boundaries. 4. Developing clearly stated objectives for use in…

For the MF-RAP, PIH-TRA, and CPD-HIM programs, ensure that the program's improper payments rate estimates adequately test for and include improper payments of Federal funding that are made by State, local, and other organizations administering these programs and adequately disclose any limitations imposed or encountered when reporting on improper payments, to a degree that fairly informs users of the respective reported information. Status

The Office of Programs should publish Railroad Medicare program payment integrity information in accordance with the Payment Integrity Information Act of 2019 and the Office of Management and Budget's data call requirements until it formalizes an agreement with the Centers for Medicare and Medicaid Services to take over reporting for Railroad Medicare.

The Office of Programs should publish improper payment estimates for the Railroad Medicare program in the Office of Management and Budget's data calls, until the Office of Management and Budget formally approves the Railroad Retirement Board's discontinuation of reporting or approves an agreement between the Centers for Medicare and Medicaid Services and the Railroad Retirement Board on how Railroad Medicare will be reported.

The Office of Programs should develop and publish corrective action plan information in accordance with the Office of Management and Budget directives.