Open Recommendations

ACF’s ORR should assess whether to establish maximum caseloads for individual mental health clinicians

ACF’s ORR should help care provider facilities improve their access to mental health specialists

ACF’s ORR should take all reasonable steps to minimize the time that children remain in ORR custody.

Continue to work with the Labor Relations department to identify opportunities to increase staffing flexibility among agreement employees, especially as the company develops maintenance strategies for the new equipment it is purchasing.

We recommend that the State agency bill for and collect from manufacturers rebates for single-source and top-20 multiple-source pharmacy and physician-administered drugs and refund to the Federal Government the estimated $28,103,346 (Federal share).

We recommend the State agency work with CMS to determine whether the other pharmacy and physician-administered drugs were eligible for rebates and, if so, upon receipt of the rebates, refund up to an estimated $47,426,944 (Federal share) our audit period and $119,561,574 (Federal share) for the nearly 4-year period before our audit period.

We recommend that the State agency ensure that all pharmacy and physician-administered drugs eligible for rebates are processed for rebates.

We recommend that the State agency develop and implement written policies and procedures for its drug rebate program.

We recommend that the State agency strengthen its NDC edit (implemented on January 1, 2015), to ensure that NDCs are captured for all drug utilization data.

We recommended the State agency improve its oversight of the LIP program by establishing policies and procedures for: o providing additional training to its staff members on the RFMD and STCs for the waiver; o providing training to participating hospital personnel on LIP program compliance and preparing the cost-limit calculations; and o monitoring hospital LIP calculations to verify that they comply with the RFMD and STCs including: ¿- reconciling hospital cost-limit calculations to the finalized Medicare cost reports; ¿- reviewing hospital low-income data to verify that it does not include data for undocumented aliens; ¿- reviewing hospital low-income data to…

We recommended that the State agency revise its LIP instruction manual to instruct participant hospitals to perform the following steps when preparing the LIP cost-limit calculations: o exclude the cost of non-emergency care for undocumented aliens; o exclude the cost of caring for prisoners in other than an inpatient setting; o review section 6 costs for allowability based on the RFMD; o distribute low-income patient days and ancillary charges to cost centers consistent with the Medicare cost report; o review the calculations for clerical errors and ensure that they exclude noncompliant items; and o reduce calculated costs by all payments…

We recommend that the State agency refund $411,932,576 to the Federal Government, consisting of: o $64,382,543, representing the Federal share of net Hospital self-reported LIP overpayments for the audit period and o $347,550,033, representing the Federal share of LIP cost limits calculated by the Hospital that did not comply with Federal and State requirements as identified in this audit.

Improve the CBMS to ensure that: o it verifies income and determines eligibility by using available electronic data sources on a timely basis, o it has system functionality to terminate Medicaid coverage for beneficiaries who do not provide satisfactory documentation to resolve a citizenship discrepancy after the reasonable opportunity period ends, o the coding errors affecting eligibility determinations are identified and addressed in a timely manner, and o it has the ability to verify income that is self-attested by beneficiaries on a timely basis and through multiple sources, to include one-to-one employer matches

Implement in the CBMS system functions to ensure o benefits of ineligible beneficiaries are terminated in a timely manner and o income verifications are requested from beneficiaries when electronic verification does not occur within 4 months of application;

Redetermine, as appropriate, the current Medicaid eligibility status of the sampled beneficiaries who did not meet Federal and State eligibility requirements, with specific attention to:[17] o beneficiaries who did not meet income requirements, o beneficiaries who were eligible under a mandatory Medicaid eligibility group, o beneficiaries who did not meet citizenship requirements, and o beneficiaries who were not eligible for the new adult group but for whom the State agency claimed enhanced Federal Medicaid reimbursement;

Improve the accuracy of manually input case actions by: o providing eligibility caseworkers with clear policies, procedures, and guidance on eligibility determinations that comply with Federal and State requirements and that address, among other things, income calculations and parent and caretaker definitions, o providing training to and monitoring of caseworkers to improve manual input accuracy, and o implementing a process to identify and review manually input eligibility data;

Implement a process whereby it resolves discrepancies more promptly by reducing the time between the identification of a discrepancy and the dispatch of a discrepancy letter to the beneficiary

Embassy Nassau should review its unliquidated obligations in accordance with Department guidelines and put up to $2.3 million to better use.

We recommended that Oceanside Medical Group refund to the Medicare program the portion of the estimated $2,694,446 overpayment for claims that are within the reopening period.

We recommended that Oceanside Medical Group, for the remaining portion of the estimated $2,694,446 overpayment for claims that are outside of the reopening period, exercise reasonable diligence to identify and return overpayments in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.

We recommended that Oceanside Medical Group exercise reasonable diligence to identify and return any additional similar overpayments outside of our audit period, in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation.

As OIG has previously recommended, CMS should work directly with hospices to ensure that they are providing drugs covered under the hospice benefit and CMS should develop and execute a strategy to ensure that Part D does not pay for drugs that should be covered by the Part A hospice benefit.

We recommend that the Texas Health and Human Services Commission work with CMS to determine whether the other physician-administered drugs, associated with 160,579 claim lines, were eligible for rebates and, if so, determine the rebates due and upon receipt of the rebates refund the Federal share of the rebates collected.

We recommend that the Texas Health and Human Services Commission bill manufacturers for the $3,785,737 ($2,202,921 Federal share) in rebates for single-source and top-20 multiple-source physician-administered drugs, and refund the Federal share of rebates collected.