Open Recommendations

Ensure that Pathfinders develops and implements comprehensive written financial policies and procedures that detail its fiscal activities and ensure compliance with the DOJ Grants Financial Guide and federal award requirements. These policies and procedures should include guidance on the appropriate allocation of costs to applicable funding sources.

Remedy the $1,800 in unsupported yoga consultant costs charged to the subawards through January 2024, as well as identify and remedy any additional unsupported yoga consultant costs charged to the subawards after January 2024.

Develop and implement guidance for DOT Operating Administrations and OST that addresses methods for estimating workforce needs-including appropriate data sources and methods for estimating workforce demand and the frequency or triggers for updating their estimates-and standards for documenting these planning procedures.

Revise departmental Infrastructure Investment and Jobs Act (IIJA) hiring reports to include the current number of onboard IIJA employees in addition to reports on IIJA hiring selections.

The Lieutenant Colonel Charles S. Kettles VA Medical Center Director confirms that acute and emergent patient transfer times related to waived infrastructure requirements are tracked and monitored, identifies trends or adverse patient outcomes, and takes actions as warranted.

The Under Secretary for Health reviews Veterans Health Administration Directive 1400.01 to confirm that the supervision of PGY-1 surgery residents and guidance provided to Veterans Health Administration facilities aligns with Veterans Health Administration policy and Accreditation Council for Graduate Medical Education program requirements.

The VA Healthcare System Serving Ohio, Indiana, and Michigan Network Director ensures the corrective actions developed by facility leaders to address surgical intensive care unit patient safety concerns are completed and evaluated for effectiveness.

Resolve the $388,319 in questioned salary costs and direct Columbia to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct Columbia to establish and implement policies and procedures or internal controls for ensuring that invoices are processed and paid within the 30-day time limit.

We recommend that USAID/Ethiopia verify that Mekdim Ethiopia National Association corrects the three instances of material noncompliance detailed on pages 35 to 38 of the audit report.

We recommend that the West Virginia Bureau for Medical Services refund to the Federal Government $2,159,071 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommend that the West Virginia Bureau for Medical Services refund to the Federal Government $14,514 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommend that the West Virginia Bureau for Medical Services work with CMS to determine the unallowable portion of $488,185 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement, refund that amount, and consider invoicing drug manufacturers for rebates for these drugs if CMS determines that the drug claims are allowable.

We recommend that the West Virginia Bureau for Medical Services strengthen internal controls for non-crossover claims going forward, to better use collected data to invoice manufacturers and collect rebates for all eligible physician-administered drugs.

We recommend that the West Virginia Bureau for Medical Services consider revising its payment methodology going forward regarding payments for crossover claims, thereby allowing collection of manufacturers' rebates for associated physician-administered drugs.

We recommend that the Centers for Medicare & Medicaid Services instruct DME MACs to do the following: Recover $11,399 in overpayments made to suppliers for the 15 sample items that did not meet Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services instruct DME MACs to do the following: Perform additional medical reviews of claims for intermittent urinary catheters and sterile catheter kits, which could have saved Medicare an estimated $35,079,833 for our audit period.

We recommend that the Centers for Medicare & Medicaid Services instruct DME MACs to do the following: Provide additional education to suppliers on documenting eligibility for intermittent urinary curved-tip catheters and sterile catheter kits and on documenting refills of catheters and sterile catheter kits. For example, CMS could emphasize the following:

-Medical records that list only a diagnosis without adequate documentation of an enrollee's inability to use a straight-tip catheter are insufficient to support medical necessity for use of a curved-tip catheter.

-Notations of urinary tract infections in medical records are insufficient to support that an enrollee is eligible for…

We recommend that the Centers for Medicare & Medicaid Services instruct DME MACs to recover $11,399 in overpayments made to suppliers for the 15 sample items that did not meet Medicare requirements.

We recommend that the Centers for Medicare & Medicaid Services instruct DME MACs to perform additional medical reviews of claims for intermittent urinary catheters and sterile catheter kits, which could have saved Medicare an estimated $35,079,833 for our audit period.

We recommend that the Centers for Medicare & Medicaid Services instruct DME MACs to provide additional education to suppliers on documenting eligibility for intermittent urinary curved-tip catheters and sterile catheter kits and on documenting refills of catheters and sterile catheter kits.

We recommend that NRC management investigate methods of identifying inactive user accounts and improving its internal controls over inactivity to ensure that it disables network user accounts after 90 days of inactivity.

The Office of General Counsel should update the Watch List procedures to include examples of risks warranting mitigating measures and what mitigating measures can be applied to parties when there is a match.

The Office of General Counsel should update the Watch List procedures to include examples of a suspicion and reputation of untrustworthy behavior and to add parties based on referrals from other agencies.

We recommend that USAID's Office of Acquisition and Assistance Cost, Audit and Support Division/Contract Audit Management Branch determine the allowability of the $42,764 ineligible questioned costs on pages 25 to 37 of the audit report and recover any unallowable amount.