Open Recommendations

Work with CMS to determine the unallowable portion of $7,889 (Federal share) for other claims for covered outpatient physician-administered drugs that were submitted without NDCs and that may have been ineligible for Federal reimbursement and refund that amount,

Work with CMS to determine whether the remaining $1,109,110 (Federal share) of other physician-administered drug claims could have been invoiced 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 all physician-administered drugs eligible for rebates are invoiced.

Work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not invoiced for rebates after December 31, 2016;

Develop and implement formal written policies and procedures for its drug rebate program.

Refund to the Federal Government $7,578,002 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement;

Refund to the Federal Government $561,937 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement;

Rec. A.1.d: The DoD OIG recommended that the Defense Security Cooperation Agency Director perform annual inspections of DoD and contractor facilities to determine the location, identification numbers, quantities, and values of the inventory on hand.

Rec. A.1.e: The DoD OIG recommended that the Defense Security Cooperation Agency Director establish definitions for all Special Defense Acquisition Fund collection sources and issue detailed accounting and reporting guidance to the implementing organizations for the transactions.

Rec. A.1.f.3: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to develop a corrective action plan to remedy any deficiencies identified during testing.

Rec. A.1.f.4: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to correct the Defense Departmental Reporting System to accept, consolidate, reconcile, and report Special Defense Acquisition Fund accounting records.

Rec. A.1.f.5: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to analyze all Foreign Military Sales cases dating back to FY 2012 to identify the correct number of lease cases.

Rec. A.1.f.6: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to analyze all open and closed Foreign Military Sales cases to determine whether the cases were properly coded in accordance with the Security Assistance Management Manual.

Rec. A.1.f.8: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to recover and transfer into the Special Defense Acquisition Fund account all authorized collections dating back to FY 2012 that the Defense Finance and Accounting Service did not transfer into the Special Defense Acquisition Fund account.

Rec. A.1.f.9: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to develop and implement internal controls to prevent the implementing organizations from improperly coding Foreign Military Sales cases.

Rec. A.1.f.10: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to obtain transaction-level detail for the Accrued Unfunded Annual Leave liability balance for all DoD employees who support the Security Assistance Accounts.

Rec. A.1.f.11: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to develop and implement standard operating procedures, process narratives, and process maps to instruct Defense Finance and Accounting Service personnel on how to record the Accrued Unfunded Annual Leave balance correctly.

Rec. A.1.f.12: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to develop and implement internal controls to ensure that all Accrued Unfunded Annual Leave transactions are recorded completely and accurately.

Rec. B.1.a: The DoD OIG recommended that the Defense Security Cooperation Agency Director review and provide written approval for each reconciliation performed by the Defense Finance and Accounting Service-Indianapolis of the Security Assistance Accounts.

Rec. B.1.b: The DoD OIG recommended that the Defense Security Cooperation Agency Director review and provide written approval for each adjustment made by the Defense Finance and Accounting Service-Indianapolis to the Security Assistance Accounts.

Rec. B.1.c: The DoD OIG recommended that the Defense Security Cooperation Agency Director develop and implement detailed standard operating procedures, process narratives, and process maps for each of the Security Assistance Accounts. The documentation should include the entire life cycle of each transaction within the Security Assistance Accounts, roles and responsibilities, internal controls, and a listing and description of interfaces with other accounting cycles and systems. Defense Security Cooperation Agency management should review the documentation annually.

Rec. B.1.d.1: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to research and resolve at the transaction level each of the transactions aged over 60 days.

Rec. B.1.d.2: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to research and resolve each of the adjustments on the FY 2017 Security Assistance Account Central Accounting and Reporting Systems statements.

Rec. B.1.d.3: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to develop and implement a Fund Balance With Treasury reconciliation process for all of the Security Assistance Accounts. The process should be documented in standard operating procedures, process narratives, and process maps.

Rec. B.1.d.4: The DoD OIG recommended that the Defense Security Cooperation Agency Director work with the Defense Finance and Accounting Service-Indianapolis Director to make the necessary corrections to the Defense Department Reporting System to collect and reconcile data so that the DoD can report all Security Assistance Account balances in the DoD Agency Financial Report.