Open Recommendations

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.

Direct UH to provide documentation that it has repaid or otherwise credited the $21,513 in questioned conference, travel, and workshop costs for which it has agreed to reimburse NSF.

Resolve the $17,787 in questioned conference, supply, currency conversion, and publication expenses for which UH has not agreed to reimburse NSF and direct UH to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct UH to provide documentation that it has repaid or otherwise credited the $19,790 in questioned fringe, conference, airfare, parking, and lodging costs for which it has agreed to reimburse NSF.

Direct UH to establish clear guidance regarding the allowability of publication expenses.

Direct UH to provide documentation that it has repaid or otherwise credited the $3,306 of questioned costs that it has agreed to reimburse.

Direct UH to provide documentation that it has repaid or otherwise credited the $9,954 in questioned costs for which it has agreed to reimburse NSF.

Direct UH to provide documentation that it has repaid or otherwise credited the $1,707 of questioned costs for which it has agreed to reimburse NSF.

Direct UH to strengthen its administrative and management procedures surrounding effort reporting. Processes could include: a. Implementing automated controls that notify the Office of Contracts and Grants of any effort charged to sponsored projects that was not certified within the required reporting window. b. Updating its current effort-reporting policies to require that personnel certify their effort within 90 days of the end of a quarterly reporting period.

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 continue researching this issue and identify all other pharmacies whose full value of the negotiated discounts were not passed through to the FEHBP.