Open Recommendations

We recommend that the BIE ensure that Chemawa Indian School enters into fundraising agreements with any non-Federal entities that solicit donations on behalf of the school.

We recommend that the BIE resolve the $593,367 in questioned costs related to the inappropriate purchases.

We recommend that the BIE develop and implement Budget and Finance policies and procedures that set forth requirements and approval processes for establishing new academic or extracurricular programs.

We recommend that the BIE develop and implement Budget and Finance policies and procedures that provide guidance regarding purchases that can be made with the different funding sources provided to the schools, including Title I funds.

We recommend that the BIE develop and implement Budget and Finance policies and procedures for approving purchase requests, including ensuring the appropriate officials certify that purchases are allowable and reasonable.

We recommend that the BIE develop and provide training to Chemawa Indian School on the newly established Budget and Finance policies and procedures for establishing new academic or extracurricular programs, defining types of purchases that can be made with the different funding sources, and approving purchase requests.

We recommend that the Assistant Secretary - Indian Affairs develop documented procedures for following protocols when constructing new facilities and for making operations and maintenance purchases of more than $2,500.

We recommend that the BIE locate or develop lease agreements with businesses using Chemawa Indian School land.

We recommend that the BIE verify that past and current lease payments are paid in accordance with the terms of the lease agreements.

We recommend that the BIE develop and disseminate policies and procedures to BIE-operated schools for establishing, managing, and overseeing leases that include, at a minimum, requirements and provisions outlined in 25 C.F.R. part 48, defined roles and responsibilities, and requirements for validating that lease payments are paid in accordance with the lease agreements.

We recommend that the BIE require Chemawa Indian School to establish a mechanism to track the location of all accountable system-controlled property.

We recommend that the BIE conduct periodic unannounced, onsite reviews at Chemawa Indian School to monitor the ongoing inventory process and verify the accuracy andcompleteness of the Indian Affairs Financial and Business Management System inventory in keeping with Indian Affairs policy.

We recommend that the BIE develop and provide training for Chemawa Indian School personnel on Indian Affairs Manual part 23 to ensure that Chemawa maintains an inventory of and tags nonexpendable property under $5,000 and to ensure understanding of requirements for expendable property tagging and recordkeeping.

We recommend that the Florida Department of Children and Families provide training to CPIs and caseworkers on medication management and administration that addresses requirements for updating case records in FSFN for children who are prescribed psychotropic medications (including related medication logs and authorizations) and opioid medications.

We recommend that the Florida Department of Children and Families coordinate with the Florida Agency for Health Care Administration to obtain access to Medicaid claim data for all children under its care and supervision.

We recommend that HAM ensure [redacted].

We recommend that HAM ensure [redacted]. Note - this recommendation cannot be implemented until the controls from Recommendation 7 are in place.

We recommend that HAM develop and then implement [redacted].

We recommend that HAM install all security-relevant software updates identified during this audit.

We recommend that HAM [redacted].

We recommend that HAM [redacted].

We recommend that HRSA identify additional improper UIP payments for services provided to insured individuals or services unrelated to COVID-19, which we estimate to be $783.6 million, and take remedial action.

We recommend that HRSA commit to strengthening its procedures that may apply to future programs of a similar nature to expand insurance verifications using additional data fields on each patient for whom an SSN is not submitted as part of a prepayment check or postpayment review process to identify potential exact matches for health insurance coverage, ensure data sources used to verify health insurance coverage are reliable, and develop in a timely manner an assessment strategy to ensure claims are appropriately reimbursed to providers.

We recommend that HRSA recover the $294,294 in improper UIP payments identified in our sample.

OIG recommends that the Bureau of Consular Affairs (CA), in coordination with the Bureau of Budget and Planning, develop and implement a risk-based methodology to select programs for evaluation. CA should include the amount of funds invested and the risk to its portfolio as factors considered in the methodology.