Open Recommendations

We recommend that Humana Health Plan, 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 Humana Health Plan, Inc. 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.

We recommend that CVS Health refund to the Federal Government the $4,256,568 of estimated overpayments.

We recommend that CVS Health 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 CVS Health continue its examination of 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.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Obtain a revised ARP EANS application from the 73 nonpublic schools thatused proportionality data (in whole or in part) to estimate its low-income student count and ensure that the schoolsinclude a revised low-income student count that is based on a proper data source. FDOE should use the revised countsto reassess the eligibility of the 73 schools and any EANS funds used to provide services to ineligible nonpublic schoolsmust be reverted to Florida’s Governor to be used for…

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Formally document its expenditure review and approval procedures to guideFDOE personnel through the expenditure review and approval processes. The procedures should be designed to ensurecompliance with applicable requirements, including those pertaining to EANS in both CRRSA and ARP EANS as well asthe regulations at 2 C.F.R. Part 200 (Uniform Guidance).

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Retroactively obtain prior written approval from the Department for the 5equipment expenditures or return the $187,660 expended for those equipment purchases and perform a review of theremaining equipment expenditures to determine whether there are additional purchases that require prior written approval.FDOE should also incorporate into its grants management policies and procedures a step to determine whether it isrequired to obtain prior approval from the Department for certain expenditures related to any Department grants, orwhether it can provide…

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Develop a process to track and periodically check on the use ofEANS-funded supply purchases with a unit cost under $5,000 to ensure that all supplies are accounted for and used forallowable purposes.

Develop a means of identifying and documenting acquisition-specific team members from the Program Offices, Division of Administration Acquisition Services Branch, Legal Division, and Office of Minority and Women Inclusion.

Update the Acquisition Procedures and Guidance Manual to (1) define “reasonable planning,” (2) require the documentation of “reasonable planning” for all acquisitions, and (3) require a written description of potential or actual acquisition-specific conflict of interest-related risks in planning documentation.

Develop procedures requiring acquisition team members, as defined in response to Recommendation 1, to complete a conflict of interest certification in which each team member is to assess and document that they do not have a potential or actual conflict of interest related to the specific acquisition prior to participating in any phase of the acquisition lifecycle (from planning to closeout). These procedures should require that evidence of acquisition team members’ conflict of interest certifications is maintained in accordance with requisite FDIC records retention schedule requirements.

Develop procedures requiring acquisition team members, as defined in response to Recommendation 1, to re-certify annually that they remain free of actual or potential conflicts of interest as long as the acquisition is in place.

Develop and deliver specialized acquisition-related conflict of interest training on at least an annual basis to all acquisition team members to strengthen employee knowledge and skills related to ethics laws and regulations.

Evaluate whether there should be minimum qualifications and requirements for appointed Deputy Ethics Counselors (DEC), a desired ratio of DECs to filers across FDIC Divisions and Offices, and whether DEC duties should be incorporated into FDIC employee position descriptions to better equip DECs to monitor and respond to employees’ potential and actual conflicts of interest.

Develop and implement an action plan utilizing Deputy Ethics Counselor survey results and other relevant information to help identify strengths and opportunities for continuous improvement in the FDIC’s financial disclosure review program.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to return to the U.S. Department of Education the $164,580 that Des Moines improperly charged tothe ARP ESSER grant for LEA advertising and public relations or reallocate the funds to other allowable costs. Identifyany additional improper charges to ESSER grants for LEA advertising and public relations, including those made duringperiods not covered by our review, and if applicable, return the funds to the U.S. Department of Education or reallocatethem to other allowable costs.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to provide documentation to support payment of the unsupported portion of the HVAC upgradesexpenditure, return to the U.S. Department of Education the $33,326 in ARP ESSER grant funds, or reallocate the fundsto other allowable costs.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to calculate the interest earned (actual or imputed) on any ESSER grant funds that were retained(withheld) and not immediately paid to vendors, and if applicable, ensure that the correct amount of interest is returned tothe Federal government in accordance with 2 C.F.R. section 200.305(b)(9).

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Iowa torequire Des Moines to ensure that LEA officials responsible for making or reviewing and approving purchases receivesufficient training on Federal rules and regulations related to grant administration and management, particularly thoseaddressing allowability, documentation requirements, and cash management.

We recommend that the Director of Acquisition and Contract Management develops standard operating procedures for issuing contract modifications.

We recommend that the Director of Acquisition and Contract Management provides training on the updated contracting procedures.

We recommend that the Director of Acquisition and Contract Management develops a contracting officer representative handbook that alights with the contracting officer representative designation memo and includes policies, standard operating procedures, and best practices to assist the contracting officer representative with contract oversight.

We recommend that the Director of Acquisition and Contract Management defines and communicates the roles, responsibilities, and standard operating procedures for the technical point of contact to ensure efficiency in executing the contract activities.

We recommend that the Director of Acquisition and Contract Management develops a centralized system for maintaining contract files to ensure that contracting officer representatives are compliant with the Federal Acquisition Regulation and record retention requirements.