Open Recommendations

CMS should Provide guidance on how MACs should account for enrollees who receive injections in both home and professional settings when performing their comparisons.

We recommend the Assistant Secretary for the Employee Benefits Security Administration pursue legislative changes regarding the authority to impose civil monetary penalties for Mental Health Parity Addiction and Equity Act violations to increase compliance with Part 7 of ERISA, which include the mental health parity provisions.

We recommend the Assistant Secretary for the Employee Benefits Security Administration pursue legislative changes regarding the authority to enforce the group health plan requirements of Part 7 of ERISA against service providers, including insurance issuers and third-party administrators for violations such as designing and applying impermissible non-quantitative treatment limitations.

We recommend the Assistant Secretary for the Employee Benefits Security Administration pursue legislative changes regarding provisions that specify remedies available for violations of Part 7 of ERISA, including the ability to force the re-adjudication of wrongfully denied claims or other remedies to restore losses resulting from Mental Health Parity and Addiction Equity Act violations.

We recommend the Assistant Secretary for the Employee Benefits Security Administration develop processes to utilize enforcement tools available to the agency, including referring health plans to the U.S. Department of the Treasury to levy the excise tax for Mental Health Parity and Addiction Equity Act violations, as appropriate.

We recommend the Assistant Secretary for the Employee Benefits Security Administration develop and issue additional guidance to support the implementation of the 2021 Consolidated Appropriations Act non-quantitative treatment limitation comparative analysis requirements and the September 2024 Mental Health Parity and Addiction Equity Act final rule, such as an updated Mental Health Parity and Addiction Equity Act Self-Compliance Tool or Frequently Asked Questions document(s).

In our February 2024 alert, we recommended that the Director, Field Assistance, take actions to address the issues we identified regarding the hours of operation, incorrect addresses, and current operational status to ensure that taxpayers have the most accurate and up-to-date information available. Additionally, immediate action should be taken to ensure that TAC facilities that are open for extended hours are accessible to taxpayers and that the hours posted at the facility are accurate and observed.

The Chief, Taxpayer Services, should develop processes and procedures to ensure that the hours of operation are accurately posted at all TAC locations and consistent with what is reflected on the IRS website. These processes and procedures should include verification steps to be taken as part of the IRS’s annual filing season readiness confirmation process.

In our February 2024 alert, we recommended that the Director, Field Assistance, and Chief, Facility Management and Security Services, take action to address the issues identified regarding the lack of security measures to ensure that taxpayers are being provided appropriate taxpayer services, and protect IRS employees and taxpayers when visiting the TACs. Additionally, processes should be implemented to ensure that all security guards are aware of their responsibilities when interacting with taxpayers to include mandatory security screening policies and refraining from impeding a taxpayer’s ability to speak with IRS employees.

In our February 2024 alert, we recommended that the Director, Field Assistance, ensure there is a consistent policy regarding whether appointments are necessary or if walk-ins will be accommodated to avoid confusion and provide a consistent experience at all TAC locations.

In our February 2024 alert, we recommended that the Director, Field Assistance, ensure all TAC employees are aware of the policies regarding walk-in taxpayers as they relate to services provided, ensure employees are aware and educated on programs offered by the IRS that will ensure that taxpayers are afforded the necessary information to obtain free services that will assist them in compliancy, and finally ensure a policy where TAC employees have the ability to print off the necessary forms requested by a taxpayer.

The Chief, Taxpayer Services, should develop processes and procedures to ensure that services offered at the TACs, including those to be provided to taxpayers without an appointment, are consistent and in conformance with internal guideline requirements. These processes and procedures should include verification steps to be taken as part of the IRS’s annual filing season readiness confirmation processes.

The Chief, Taxpayer Services, should perform a cost-benefit analysis to ensure a business need, including a benefit to the taxpaying public, continues to exist in providing local TAC telephone lines.

The Chief, Taxpayer Services, should develop processes and procedures to ensure the accuracy and consistency of recorded messages while local telephone lines continue to be in place. These processes and procedures should include verification steps to be taken as part of the IRS’s annual filing season readiness confirmation processes.

We recommend that USAID/West Africa determine the allowability of $39,329 in unsupported costs on pages 11, 12 to 14 of the audit report and recover any amount that is unallowable.

We recommend that USAID/West Africa verify that National Episcopal Conference in Cameroon corrects the four material weaknesses in internal control detailed on pages 17 to 21 of the audit report.

We recommend that USAID/West Africa verify that National Episcopal Conference in Cameroon corrects the two instances of material noncompliance detailed on pages 21 and 22 of the audit report.

We recommend that USAID/Southern Africa determine the allowability of $25,847 in ineligible questioned costs on page 20 of the audit report and recover any amount that is unallowable.

We recommend that the Mental Health Center of Florida monitor and evaluate the effectiveness of the QA program updates to ensure that documenting of time spent on psychotherapy services meets Medicare requirements.

We recommend that the Mental Health Center of Florida monitor and evaluate the effectiveness of the QA program updates to ensure that documenting of time spent on psychotherapy services meets Medicare requirements.

We recommend that the Massachusetts Executive Office of Health and Human Services recover from IMDs and CBDCs $21,606,437 in SNCP payments that exceeded the cost of caring for Medicaid and uninsured patients.

We recommend that the Massachusetts Executive Office of Health and Human Services correct its $6,239,386 overstatement of CPEs on the CMS-64, which represents the difference between its CPE estimates and the actual uncompensated care provided to uninsured patients for State-owned hospitals.

We recommend that the Massachusetts Executive Office of Health and Human Services refund to the Federal government the $13,922,912 Federal share of the total $27,845,823 in SNCP expenditures that did not comply with Federal requirements.

We recommend that the Massachusetts Executive Office of Health and Human Services develop and implement policies and procedures that instruct personnel to perform interim and final reconciliations required by the STCs.

We recommend that the Massachusetts Executive Office of Health and Human Services perform reconciliations for the SFYs following our audit period, where the required Medicare cost reports or UFRs are available. In addition, it should refund the Federal share of any oversated CPEs, as well as recover any overpayments to IMDs and CBDCs and refund the Federal share.