Open Recommendations

Direct USAC to modify testing procedures for verification reviews to ensure that the deployment date tested by the Verification Team is reflective of the date entered and certified in HUBB by the carrier and supported by appropriate evidence.

Direct USAC to develop and implement procedures that identify possible erroneous deployment dates and document whether a change to past-compliance statuses is warranted. Further, USAC should determine if any of the payments made to these
carriers would be considered an improper payment.

Direct USAC to modify testing procedures for verification reviews to ensure that carriers are offering the speeds per the corresponding program requirements for minimum speeds. Examples of testing procedures include reviewing stronger evidence, such as an engineer certification or actual network speed testing results performed by a third party or through collaboration with USAC’s engineers.

Develop and disseminate guidance to assist DOJ components in determining when a document constitutes a nondisclosure policy, form, or agreement subject to inclusion of the WPEA-required statement. This guidance should provide clarity on the terms "policies," "forms," or "agreements" because the WPEA does not define those terms.

Require all components to review documents identified by using the guidance developed as a result of recommendation number 1 and revise or update all such documents, as appropriate, to ensure they incorporate the full statutory language at 5 U.S.C. 2302(b)(13)(A).

Ensure that all personnel responsible for processing prisoner medical request and performing medical claim reviews are properly notified of all recent and future requirement changes.

Perform an assessment of its prisoner medical request and medical claim review processes and implement a formal strategy that seeks to centralize critical functions where appropriate and considers modernizing elements of these processes to ensure the most effective and efficient administration of this critical program, including electronic processing. Such processing would enable the USMS to employ data analytical tools in its reviews of medical claims, thereby enhancing its controls and identification of problem areas.

Develop a strategy for obtaining and paying for dental care to maximize cost effectiveness. As part of this effort, the USMS should explore cost saving opportunities, including negotiating dental pricing in its contract solicitation or negotiating prices of common dental procedures with dental providers in order to reduce the variance in prices charged to the USMS.

Evaluate the access to care provided to USMS prisoners for dental services and ensure consistent access to care is provided throughout the 95 USMS districts.

Remedy the $7,841 in unallowable dental services identified by the OIG.

Improve the notification process for preauthorization of prisoner medical requests entered into Capture to better ensure timely medical services for USMS prisoners.

Remedy the remaining $37,416 of the $43,311 in unsupported medical claims for which the USMS requested recoupment from the medical service providers.

Develop internal control procedures that help ensure that all prisoner medical requests are entered into Capture and help prevent district office personnel from approving medical claims for payment without proper POD-OMO review and approval support in Capture.

Re-evaluate its auto-approval process to ensure that only medically necessary services are approved within the limits set by USMS policy, especially as it relates to dental services.

Remedy the $33,830 in unallowable medical services identified by the OIG.

Assess the risk associated with the remaining historical costs under this contract to determine if additional recoupment efforts are appropriate and cost beneficial.

Enhance its prisoner medical request and medical claim review training. Specifically, the USMS should : (1) ensure all remaining district office personnel responsible for processing prisoner medical requests and medical claim reviews receive formal training from POD-OMO; (2) revise its procedures to ensure newly assigned prisoner medical request and medical claim review personnel also receive the same training prior to assuming these responsibilities; and (3) provide appropriate medical billing training to help district office personnel more easily match medical services to preauthorization's and identify medical claim deficiencies.

Evaluate the impact on the USMS's core mission and on the efficiency of the provision of medical care to prisoners when assigning Deputy U.S. Marshals to the prisoner medical request process.

Remedy the $748,998 in unsupported costs.

Put to better use the remaining $1,000 in grant funds awarded to CFSS.

Apply appropriate measures to confirm the adequacy of CFSS's accounting and internal control systems prior to making future awards to CFSS to ensure federal funds are safeguarded.

Provide training to ISSPOs, ISOs, and Information Owners on their roles and responsibilities to follow the PBGC RMF and POA&M processes.

Confirm the requirement that deficiencies identified by SPA&A reviews that are not remediated within 30 days after identification are tracked via POA&Ms with accountable personnel.

Periodically monitor the satisfaction of the system risk assessment and POA&M creation requirements to help ensure ongoing compliance associated with the timely completion of and updates to system risk assessments and documentation and tracking of POA&Ms.

We recommend PBGC management to coordinate with its CSP to update its service agreement and shared responsibility matrix to address ambiguities regarding accountable parties for key controls and develop and implement a contingency plan for the system.