Open Recommendations

We recommend the Assistant Secretary for Occupational Safety and Health: Modify the Field Operations Manual to include a policy for mandatory interviews of complainants and witnesses or document the rationale for lack thereof and provide training to Compliance Safety and Health Officers on the updated requirements.

We recommend the Assistant Secretary for Occupational Safety and Health: Update the Field Operations Manual to require documented case file review and approvals by supervisors and provide training for Compliance Safety and Health Officers to ensure complete documentation of significant decisions and actions.

We recommend the Assistant Secretary for Occupational Safety and Health: Establish controls and provide training of Field Operations Manual abatement certification and documentation requirements and create a monitoring process that is reviewed and approved by a supervisor.

We recommend that OPM direct its carriers to issue guidance to members and providers on telehealth billing, privacy and security, and quality of care risks.

We recommend that OPM develop and maintain a list of services that can be provided via telehealth and require carriers to place edits in their claims systems that will check telehealth claims against this list. Any telehealth claims with procedure codes indicating services not on this list should pend for medical review prior to payment. OPM could start with the list maintained by CMS, expanding the allowed services if desired.

We recommend that OPM specify the telehealth technology laws and regulations with which FEHBP providers must comply or create its own list of requirements, if preferred, and require FEHBP carriers to ensure providers are implementing these requirements.

We recommend that OPM consult with the Office of the General Counsel (OGC) to determine the legal sufficiency of OPM's preemptive authority to implement a uniform framework requiring FEHBP providers to obtain informed consent from all parties before recording audio or video telehealth sessions. Should OGC conclude that OPM's preemptive authority is not sufficient to require FEHBP providers to obtain informed consent in all circumstances, then we recommend that OPM issue guidance to FEHBP carriers recommending that FEHBP providers obtain informed consent, where required by existing and applicable authorities. Regardless of OGC's determination, we also recommend that the guidance OPM…

We recommend that OPM direct carriers to review their claims system edits as they relate to telehealth claims and to implement appropriate claim audits and/or data analytics to identify potentially fraudulent, wasteful, or abusive telehealth billing practices.

We recommend that the Deputy Assistant Secretary for Public Housing and Voucher Programs enhance SEMAP or develop a new performance measurement process that would identify PHAs with underperforming HCV Programs, which should include an assessment of PHAs' ability to maximize assistance to house families.

We recommend that the Deputy Assistant Secretary for Field Operations provide training and guidance to field office program staff on SEMAP scoring, rating, and verification procedures, including confirmatory reviews, quality control reviews, and adjustments, as appropriate, for the revised SEMAP process.

Establish a formal process to monitor and track expenditures when grantees’ expenditures exceed the $750,000 threshold to identify if compliance audits are required and verify that the audits, past due and future, are performed.

Provide refresher or updated training to staff regarding the requirements and processes for reviewing auditees’ reporting packages.

Ensure Contracting Officers make a determination on the allowability of any questioned costs from past due audits when completed.

Establish a formal process to monitor and track expenditures when grantees’ expenditures exceed the $750,000 threshold to identify if compliance audits are required and verify that the audits, past due and future, are performed.

Ensure Contracting Officers make a determination on the allowability of any questioned costs from past due audits when completed.

Ensure that Department Order 470.5 is updated to provide more descriptive guidance for LITWGs and add the roles and responsibilities for the Office of Insider Threat.

Ensure that the ARC is receiving insider threat information from LITWGs to be collected and integrated to generate referrals for detection, mitigation, and analysis for the ITP to respond to insider threats

Implement cross-organizational communication and collaboration with LITWGs to ensure that referrals with the ARC are addressed, as required

Implement cross-organizational communication and collaboration with LITWGs to ensure that referrals with the ARC are addressed, as required.

Ensure that Department Order 470.5 is updated to provide more descriptive guidance for LITWGs and add the roles and responsibilities for the Office of Insider Threat.

Ensure that the ARC is receiving insider threat information from LITWGs to be collected and integrated to generate referrals for detection, mitigation, and analysis for the ITP to respond to insider threats.

We recommend that the Director of CPD's Office of Disaster Recovery adopt LMI benchmarking to ensure that grantees budget adequate funds to LMI at significant milestones in the grant lifecycle.

We recommend that the Director of CPD's Office of Disaster Recovery make changes to the action plan process so that the action plan calculates an overall LMI percentage.

We recommend that the Florida Agency for Health Care Administration invoice for, and collect from manufacturers, an estimated $57,700 ($35,126 Federal share) in rebates for single-source physician-administered drugs and refund the Federal share of rebates collected.

We recommend that the Florida Agency for Health Care Administration ensure that all physician-administered drugs eligible for rebates after our audit period are processed for rebates.