Open Recommendations

We recommend that Blue Care Network of Michigan continue to examine its existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

We recommend that Blue Care Network of Michigan refund to the Federal Government the $3,412,369 of estimated overpayments.

We recommend that Blue Care Network of Michigan identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before or after our audit period and refund any resulting overpayments to the Federal Government.

We recommend that Blue Care Network of Michigan continue to examine its existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

The Office of the Chief Financial Officer establishes guidance to monitor and report on value-added tax submissions processed by the Embassy.

The Director of Management and Operations reconciles the outstanding bills of collection for value-added tax against the collections posted in the Voucher Auditor Detail Report.

The Director of Management and Operations complies with Federal law, regulations, and agency policy when procuring food, accommodations, and other costs for Personal Service Contract staff attending retreats and trainings; inquire with the Office of the Chief Financial Officer regarding exceptions to the policy; and document decisions made.

The Peace Corps conducts an internal review of the questioned costs and works with the Government Accountability Office to determine if the questioned costs result in Anti-deficiency Act violations.

The Director of Management and Operations provides additional oversight to ensure that invoices paid by the post reflect the agreed upon contract amounts, and in accordance with Peace Corps’ policy, to modify the contract when material changes occur.

The Director of Management and Operations ensures that property management personnel are fully trained on using the property management system and establishes specific standard operating procedures to ensure all accountable assets are reviewed and recorded accurately in the asset management system by post staff that manage property.

The Office of the Chief Financial Officer and Office of Management develop additional guidance to ensure the property meeting the capitalization threshold is accounted for and capitalized, including those purchased from multiple vendors, are reviewed, and recorded accurately in the fixed asset records.

The Director of Management and Operations ensures property disposal requests are approved prior to changing the property system records and disposing the assets.

The Director of Management and Operations ensures post property is accurately accounted for in the asset management system by conducting physical inventory verifications, resolving discrepancies, and maintaining organized storage areas to locate the assets.

The Office of the Chief Financial Officer follows-up with the individual program offices to de-obligate the outstanding obligations.

The Director of Management and Operations and Principal Cashier ensure prior advances are reconciled and cleared before disbursing additional advances, within the authorized limits.

The Director of Management and Operations reviews the interim advances and develops a plan of action to ensure that advances are cleared within 3 days.

The Director of Management and Operations develops additional standard operating procedures to ensure cash verifications are conducted for remote sub-cashiers.

The Office of the Chief Financial Officer collects or waives the bill of collection for overpaid living allowance totaling $388 U.S. dollar equivalent and consider additional guidance on how Posts should handle these situations.

The Director of Management and Operations ensures that the post administrative staff collaborate with the Office of the Chief Financial Officer to cancel future Volunteer allowance payments as soon as the post is aware that the Volunteer is terminating service and work with the banks to retrieve funds if the payments are posted to the Volunteer’s account.

The Director of Management and Operations conducts training and reviews record retention requirements with post staff to ensure documentation is retained in accordance with Peace Corps guidance.

The Office of Records Management updates the Manual Section 892 guidance to allow post staff to maintain Personal Service Contract records electronically in addition to paper documentation.

The Director of Management and Operations reviews holiday and premium pay for other hourly Personal Service Contracts and determines if any additional collections are needed and then issue bills of collection or waive the collection. If needed, provide training on payroll calculations.

The Director of Management and Operations ensures the post follows guidance when processing Personal Service Contract awards and seeks approval from the Office of the Chief Financial Officer before deviating from it.

The Country Director ensures that disposals are conducted in accordance with Peace Corps policies by removing expired or wasted medication timely from the shelves, waiting to remove expired medication from the inventory logs until disposal has taken place, and witnessing contamination of expired medication.

Embassy Brazzaville, in coordination with the Bureau of Democracy, Human Rights, and Labor and the Bureau of African Affairs, should bring its Leahy vetting practices into compliance with the embassy's standard operating procedures and Department guidance.