Open Recommendations

Identify and document the characteristics of items that are to be placed under Configuration Management control (Configuration Management vii).

Establish measures to evaluate the implementation of changes in accordance with documented information system baselines and integrated secure configurations (Configuration Management vii).

Define and document a strategy (including specific milestones) to implement the Federal Identity, Credential, and Access Management architecture (Identity and Access Management i/ii/iii).

Integrate Identity, Credential, and Access Management strategy and activities into the Enterprise Architecture and Information Security Continuous Monitoring (Identity and Access Management i/ii/iii).

Develop, formalize (through the CPSC’s D-100 process), and implement processes to ensure all personnel are assigned risk designations and appropriately screened prior to being granted access to agency systems. Prior to formalizing the existing risk designation procedures, these procedures should be enhanced to include the following requirements:• Performance of periodic reviews of risk designations at least annually,• Explicit position screening criteria for information security role appointments, and• Description of how cybersecurity is integrated into human resources practices (Identity and Access Management iv).

Define and implement a process to ensure the completion of access agreements for all CPSC users. (Identity and Access Management v).

Define and implement the identification and authentication policies and procedures (Identity and Access Management ii).

Define and implement processes for provisioning, managing, and reviewing privileged accounts (Identity and Access Management vii) (2021 recommendation).

Document and implement a process for inventorying and securing systems that contain Personally Identifiable Information or other sensitive agency data (e.g., proprietary information) (Data Protection and Privacy i).

Document and implement a process for periodically reviewing for and removing unnecessary Personally Identifiable Information from agency systems (Data Protection and Privacy i).

Identify all CPSC personnel that affect security and privacy (e.g., Executive Risk Council, Freedom of Information Act personnel, etc.) and ensure the training policies are modified to require these individuals to participate in role-based security/privacy training (Data Protection and Privacy iii).

Perform an assessment of the knowledge, skills, and abilities of CPSC personnel with significant security responsibilities (Security Training i).

Document and implement a process for ensuring that all personnel with significant security roles and responsibilities are provided specialized security training to perform assigned duties (Security Training ii/iii) (2021 recommendation).

Develop and tailor security training content for all CPSC personnel with significant security responsibilities and provide this training to the appropriate individuals (Security Training iv/v).

Integrate the established strategy for identifying organizational risk tolerance into the Information Security Continuous Monitoring plan (Information Security Continuous Monitoring i).

Implement Information Security Continuous Monitoring procedures, including those procedures related to the monitoring of performance measures and metrics , that support the Information Security Continuous Monitoring program (Information Security Continuous Monitoring ii) (2021 recommendation).

Develop, document, and distribute all required Contingency Planning documents (e.g.. organization-wide Continuity of Operation Plan and Business Impact Assessment, Disaster Recovery Plan, Business Continuity Plans, and Information System Contingency Plans) in accordance with appropriate federal and best practice guidance (Contingency Planning ii/iv).

Integrate documented contingency plans with the other relevant agency planning areas (Contingency Planning iii).

Develop a comprehensive strategic plan for transitioning to a fully digital security camera system that, among other things:a. identifies enhancements needed to address camera functionality and coverage deficiencies, b. provides cost projections and the BOP appropriations account to fund the upgrades, andc. includes an estimated timeline for completion of the work.

We recommend that Coventry Health Care of Missouri, Inc. refund to the Federal Government the $548,852 of total net overpayments.

We recommend that Coventry Health Care of Missouri, Inc. identify, for the diagnoses included in this report, instances of noncompliance in the enrollee-years that occurred: (1) during our audit period but were not included in our judgmental sample and (2) before and after our audit period and refund any resulting overpayments to the Federal Government.

We recommend that Coventry Health Care of Missouri, Inc. enhance its compliance procedures to focus on diagnosis codes that are at high risk for being miscoded by 1) educating its providers about the proper use and documentation of these diagnoses and 2) determining whether these diagnosis codes (when submitted to CMS for use in CMS's risk adjustment program) comply with Federal requirements.

This recommendation is Sensitive But Unclassified.

This recommendation is Sensitive But Unclassified.

USDA OIG has determined that this recommendation contains sensitive information and will not be publicly released due to privacy concerns.