Open Recommendations

Provide documentation, or a full and detailed explanation, of the process Michigan used to determine that the four education-related entities that received GEER grant funds were essential for carrying out emergency educational services, providing childcare and early childhood education, providing social and emotional support, or protecting education-related jobs.

Develop and implement a process to ensure that it documents the criteria and decisions made for awarding future GEER grant funds in accordance with applicable requirements.

Take appropriate action if the documentation and other information provided by Michigan in response to the above recommendations does not support that the State followed applicable requirements.

Timely design and implement a monitoring plan that will ensure that K–12 GEER and Early On program subgrantees’ use of GEER grant funds complies with the CARES Act and other applicable Federal requirements. The monitoring plan should include protocols to review, on at least a sample basis, and using a riskbased approach, supporting documentation for subgrantee expenditures charged to the GEER grant to provide assurance that funds were used for allowable purposes.

Develop and implement a process to review, on at least a sample basis, and using a risk-based approach, supporting documentation and award calculations for the FFF Path 1 scholarship awards.

OIG recommends that the Bureau of Diplomatic Security (a) determine whether the $361,627,297 in questioned costs spent on Contract 19AQMM19C0007 are supported and allowable and (b) recover any costs determined to be unsupported and unallowable.

We recommend that Regence BlueCross BlueShield of Oregon refund to the Federal Government the $1,890,855 of estimated net overpayments.

We recommend that Regence BlueCross BlueShield of Oregon 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 Regence BlueCross BlueShield of Oregon continue to examine its existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

Thoroughly review each COVID-19 EIDL, grant, and advance application submitted from foreign IP addresses that were approved and funded and verify eligibility. If ineligibility or evidence of potential fraud is found, SBA should stop any further or future disbursements, recover any disbursed funds, and refer fraudulent loans to OIG for investigation.

Examine controls related to foreign IP addresses and ensure these controls are more effective in future disaster processing systems.

We recommend that the New York State Department of Health refund the estimated $84,329,893 to the Federal Government for payments that did not comply with Federal and State requirements.

We recommend that the New York State Department of Health work with the transportation manager to review the payments to transportation providers that may not have complied with Federal and State requirements, resulting in an estimated $112,028,279 in Federal Medicaid reimbursement, and refund to the Federal Government any unallowable amounts.

The FHFA Office of General Counsel’s Designated Agency Ethics Official or Alternate Designated Agency Ethics Official should improve the Agency’s existing internal controls over its employee financial disclosure process by performing and documenting technical reviews and conflict of interest analysis within 60 days of receiving employee financial disclosure reports as required by OGE regulations and FHFA policy.

FHFA should improve existing internal controls over its employee financial disclosure process by ensuring that employees file their financial disclosure reports timely as required by the U.S. Office of Government Ethics regulations and FHFA policy.

Implement and document in appropriate policy and procedures a process to validate whether minority depository institutions continue to meet the minority depository institution definition.

The Indian Health Service should develop a strategy for expeditiously deploying a new information system when it is necessary to meet an urgent, mission-critical need. The strategy should define the minimum set of controls out of the total number of required controls that should be addressed and, if applicable tested, before the new system is authorized to operate until it is feasible to address all required controls. The authorization to operate should include an acceptance of risk for not implementing all required controls, specify a date by which the remaining required controls will be implemented and tested, and be replaced…

The Indian Health Service should ensure adequate policies, procedures and training are implemented to ensure that known vulnerabilities that may impact the telehealth technologies are remediated in a timely manner.

We recommend the Secretary of Homeland Security develop a comprehensive contingency plan to support similar emergency situations in the future and account for, screen, vet, and inspect all individuals during unprecedented events when limited biographic data is available. Specifically:
a.
The plan should include, at a minimum, lessons learned from departmental after-action reports that can be incorporated into the plan for future events, lead roles and responsibilities, points of contact, established processes, and expected timeframes.
b.
The policies and procedures should ensure accountability, standard practices, and quality assurance across DHS components involved in screening, vetting, and inspecting individuals in emergency…

Improve policies, procedures, and guidance to clearly define the last major facility life cycle stage and define how NSF will carry out these transitions. These documents should identify steps for managing the transition, for designating and identifying internal resources to facilitate the process, and for obtaining required reviews and approvals.

OIG recommends that the Bureau of Intelligence and Research finalize the draft “Large Scale International Boundary Update Process Documentation” and approve the document for use.

Sensitive But Unclassified

We recommend that the Administration for Strategic Preparedness and Response: • establish written policies and procedures regarding the roles and responsibilities for organizational communication between ASPR and federally established emergency response team lead agencies;

We recommend that the Administration for Strategic Preparedness and Response make corrections in the FPDS for the four contracts for which ASPR reported inaccurate contract data, as detailed in our report.

We recommend that the Administration for Strategic Preparedness and Response: develop and implement policies and procedures to help ensure the accurate reporting of contract data in FPDS.