Open Recommendations

We recommend that the California Department of Health Care Services work with the selected provider to improve the quality of care provided to beneficiaries by correcting deficiencies.

Develop, implement, and formally communicate a process to ensure review of all proposed Information Sharing Access Agreements involving personally identifiable information.

We recommend that the Choctaw Nation of Oklahoma strengthen policies and procedures by clarifying responsibilities between and within Tribal departments for the review and approval of costs submitted on contractor invoices.

Resolve the $412,363 in questioned subaward costs and direct UF to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct UF to strengthen the administrative and management internal controls and processes over transferring significant parts of NSF funded research to other organizations. Processes could include: a. Establishing procedures that require UF to verify that, for any subaward established to perform research under an NSF grant awarded to UF, it specifically obtained the NSF Grants Officer’s approval, either as part of the NSF grant budget or through a formal request to transfer the research or effort through NSF’s FastLane system, before issuing a subaward. b. Requiring periodic training for Principal Investigators and other personnel permitted to issue subaward agreements under…

Resolve the $47,226 in questioned participant support, travel, and publication expenses for which UF has not agreed to reimburse NSF and direct UF to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct UF to provide documentation that it has repaid or otherwise credited the $66,590 of questioned participant support, travel, other direct, and indirect costs for which it has agreed to reimburse NSF.

Direct UF to establish clear guidance regarding the use of participant support cost funding. This guidance should address: a. What types of expenses can be covered by participant support cost funding. b. When to charge project codes dedicated to accumulating participant support costs. c. When and how to request approval to re-budget participant support cost funding, as well as how to document the approval. d. When it is permissible to use participant support costs to provide meals or refreshments during a conference, including how to segregate and account for unallowable participant support costs, such as costs associated with employee meals…

Direct UF to strengthen its administrative and management procedures and internal controls surrounding the purchase of airfare and the approval of travel expense reports. Updated procedures could include: a. Conducting annual training for those individuals responsible for reviewing and approving expense reports within each department. b. Establishing clear guidance regarding the allowability of airfare, lodging, and other travel expenses for accompanying individuals and individuals who did not attend grant-related conferences and whose travel therefore does not benefit the project(s) charged.

Direct UF to strengthen its administrative and management procedures and internal controls surrounding the processing of tuition waivers and relocation expenses to ensure that it only charges NSF for allowable fees and approved relocation allowances.

Direct UF to establish clear guidance regarding the allowability of publication expenses on sponsored projects, including the need to acknowledge NSF funding sources.

Resolve the $83,227 in questioned supplies, software, severance and publication costs for which UF has not agreed to reimburse NSF and direct UF to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct UF to provide documentation that it has repaid or otherwise credited the $29,600 in questioned lab supplies, materials, travel costs, and tuition fees for which it has agreed to reimburse NSF.

Direct UF to strengthen its administrative and management procedures, internal controls, and processes for allocating salary, publication, material and supply, travel, and tuition expenses to sponsored projects. Processes could include: a. Requiring Principal Investigators or other designated staff to both document and justify the allocation methodologies they use to charge expenses to sponsored projects. b. Establishing clear guidance regarding the treatment of severance pay, including how to reasonably allocate expenses of this nature to sponsored projects. c. Establishing clear guidance and training regarding the allowability of publication costs. Specifically, the guidance and training should emphasize the requirement that personnel (i)…

Direct UF to provide documentation that it has repaid or otherwise credited the $1,717 of questioned graduate student stipend costs for which it has agreed to reimburse NSF.

Direct UF to update its current procedures and internal controls for reviewing stipend costs charged to Graduate Research Fellowship Program awards. Updated procedures should require UF to periodically review all stipend payments to ensure that UF appropriately calculated the stipend amounts paid.

Direct UF to strengthen its directives/procedures and internal controls for procuring goods and services related to sponsored projects. Processes could include: a. Conducting annual training for those individuals who are responsible for approving service expenses that require a sole-source justification form, a requisition form, and appropriate approvals before the vendor or consultant begins providing the services. b. Implementing a control to flag purchases of goods and services that exceed the thresholds identified in UF’s current procurement policies.

Direct UF to strengthen its directives/procedures and internal controls surrounding the completion of Cost Accounting Standards exemptions. Specifically, the updated procedures should prevent UF from charging general-purpose computing devices directly to sponsored projects without a documented, approved exemption.

Direct UF to strengthen its directives/procedures and internal controls for incurring travel costs related to sponsored projects. Processes could include conducting annual training for those individuals who charge travel expenses to federally sponsored projects. The training should specifically address how to ensure that the individuals obtained the appropriate advance approvals for student travel, that they are receiving the appropriate per diem rate, and that they settle and complete travel advances and expense reports in a timely manner.

Direct UF to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.

We recommend that the Centers for Medicare & Medicaid Services review the list of 100 error-prone providers identified in this audit and take specific action as appropriate, such as prior authorization, prepayment reviews, and postpayment review.

We recommend that the Centers for Medicare & Medicaid Services use annual CERT data to identify individual providers that have an increased risk of receiving improper payments and apply additional program integrity tools to these providers.

Update the I-9 Guide to include minimum elements ICE officials must document in case files to justify fine reductions.

Assess I-9 processes and update the I-9 Guide to ensure it addresses risks and challenges, including:a. when employers make corrections to address substantive violations and when employers claim they were unaware that they employed Unauthorized Alien Workers;b. ICE’s ability to conduct follow-up inspections with limited resources; andc. when I-9 inspections identify individuals using fraudulent documents to obtain unlawful employment.

Develop and implement a quality assurance process that allows ICE headquarters to sample cases on an objective, periodic basis, to determine whether field offices reduce fines, issue compliance letters, and conduct follow-up inspections of employers in accordance with ICE policies and procedures.