Open Recommendations

We recommended that the State agency consider having Complaint Intake be the initial recipient of all incident reports from nursing facilities to assist in conducting more effective and timely investigations of all aspects of an allegation within incident reports.

We recommend that the Deputy Commissioner of CBP develop and implement policies to ensure CBP's covert testing groups: a. develop risk-based annual covert test plans and identify systemic tests; b. distribute test results throughout the organization; c. make recommendations; and d. implement and track corrective actions.

We recommend that the Assistant Commissioner of Office of Intelligence and Border Patrol's Chief of Law Enforcement Operations Directorate direct covert testing entities to develop and implement both performance measures and standard operating procedures including: a. processes for determining data to be included in test reports, b. data quality monitoring, and c. supervisory review.

We recommend that the Assistant Commissioner of the Office of Intelligence direct all Operational Field Testing Division staff to review all prior and future classified reports to ensure they are properly marked to protect national security information.

Identify and recover capitation payments made on behalf of deceased beneficiaries before and after our audit period, and repay the Federal share of amounts recovered

Create system edits to help identify overpayments and failures in the automated interfaces between the eligibility, payment, and death data

Use additional sources of date of death consistently to help reduce unallowable payments

Refund $13,696,760 Federal share to the Federal Government

We recommend FEMA develop guidance, including the appropriate milestones in the grant lifecycle, for assessing costs under a T&M contract for reasonableness and eligibility.

We recommend that the New Jersey Department of Human Services continue to work with ACF to reach substantial compliance with criminal background check requirements.

We recommend that the New Jersey Department of Human Services develop a system that provides notifications to State agency staff when criminal background checks need to be conducted for prospective and current employees and household members.

Given the sensitivity of our review, this recommendation is restricted.

Direct the MACs to recover the $41,613 in identified overpayments made to HHAs for the sampled claims.

Require the MACs to perform data analysis and risk assessments of claims with visits slightly above the applicable LUPA threshold and target these claims for additional review.

Instruct the MACs to educate HHA providers on properly billing for home health services with visits slightly above the applicable LUPA threshold, which could have saved Medicare as much as $191,773,995 during our audit period.

We recommend that the Health Resources and Services Administration ensure that it follows its policy for timely responding to health centers’ requests to carry over grant funds.

We recommend that the Health Resources and Services Administration assess health centers’ progress toward meeting AIMS grant award conditions to increase personnel and patients’ access to care and follow up with appropriate corrective action, such as providing technical assistance or discontinuing or reducing future AIMS grant funds.

We recommend that the Health Resources and Services Administration review BPRs to identify health centers that did not report progress toward meeting their health IT or training goals.

We recommend that On-Site Psychological Services, P.C.refund to the Medicare program the estimated $3,373,440 overpayment.

We recommend that On-Site Psychological Services, P.C. based upon the results of this audit, exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule25 and identify any of those returned overpayments as having been made in accordance with this recommendation

Work with CMS to determine whether the remaining $300,266 ($185,066 Federal share) for claims for other physician-administered drugs could have been billed to the manufacturers to receive rebates and, if so, upon receipt of the rebates, refund the Federal share of the manufacturers’ rebates for those claims.

Strengthen its internal controls to ensure that it bills manufacturers for rebates for all physician-administered drugs that are eligible for rebates.

Work with CMS to determine the unallowable portion of $7,229 ($3,615 Federal share) for claims for other physician-administered drugs that were submitted with invalid NDCs and that may have been ineligible for Federal reimbursement and refund that amount.

Work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not billed for rebates after December 31, 2017.

We recommend that the PBM return $834,425 to the Carrier (to be credited to the FEHBP) for failing to provide pass-through pricing to the FEHBP at the full value of the PBM’s negotiated discounts with Walgreens and Rite Aid retail pharmacy claims for CYs 2014 through 2016.