Open Recommendations

We recommend that Saint Francis Health Center 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.

We recommend that the Centers for Medicare & Medicaid Services correct the bona fide needs obligation violations totaling $164,606,982 ($155,866,794 related to the Federal marketplace) and, if CMS is unable to correct those violations, report the Antideficiency Act violations

We recommend that the Centers for Medicare & Medicaid Services correct the bona fide needs expenditure violations totaling $22,386,227 ($18,269,216 related to the Federal marketplace) and, if CMS is unable to correct those violations, report the Antideficiency Act violations

Embassy Canberra, in coordination with the Bureaus of Overseas Buildings Operations and East Asian and Pacific Affairs, should dispose of property numbers R48 and R49 at Kalgoorlie Crescent in accordance with Department guidelines and put up to $896,849 to better use.

We recommend the Office of Response and Recovery, Associate Administrator take steps to maintain a complete set of supporting documentation, including invoices and bills of lading to support all of its MHU and TPS assets. FEMA should also align its recordkeeping with Office of Management and Budget Circular A-123 and the Federal Acquisition Regulation by establishing documentation processes that include audit trails and specific document retention periods.

We recommend that CHI St. Vincent Infirmary amend the 33 claims (10 incorrectly amended and 23 not amended) to identify and return any improper outlier payments that are within the 4-year claims reopening period

We recommend that CHI St. Vincent Infirmary exercise reasonable diligence to identify and return any additional similar overpayments (including overpayments received during our audit period for the remaining $1,072,249 in outlier payments that we did not review and 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.

We recommend that CHI St. Vincent Infirmary return the $362,999 in improper outlier payments for the 70 claims that have been amended correctly.

We recommend that CHI St. Vincent Infirmary improve procedures and provide education to ensure claims billed to Medicare are accurate.

We recommend that the New York State Department of Health refund $11,257,368 to the Federal Government

We recommend that the New York State Department of Health identify and recover improper managed care payments made to different MCOs on behalf of beneficiaries with multiple Medicaid ID numbers prior to and after our audit period, and repay the Federal share of the amounts recovered

We recommend that the New York State Department of Health strengthen its procedures for determining whether an individual applying for Medicaid has already been assigned a Medicaid ID number by ensuring that: - its system queries identify all individuals with existing Medicaid ID numbers and - local district and Marketplace staff follow guidance on identifying individuals with Medicaid ID numbers and use all available resources to identify and prevent the issuance of multiple Medicaid ID numbers to the same individual.

We recommend that the New York Department of Health refund to the Federal Government $146,672 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

We recommended that the New York Department of Health work with CMS to determine the unallowable portion of $2,340,390 (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, and whether the remaining $714,777 (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.

We recommend that the New York Department of Health refund to the Federal Government $3,197,404 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement

We recommended that the New York Department of Health 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, 2017.

We recommended that the New York Department of Health strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced.

We recommend the Acting Director, U.S. Immigration and Customs Enforcement, conduct an independent workforce analysis to determine whether centralizing research of aliens and issuing detainers at the Pacific Enforcement Response Center would be more efficient than performing these tasks there as well as at local research centers.

We recommend that the Michigan Department of Health and Human Services refund $27,545,800 to the Federal Government

We recommend that the Michigan Department of Health and Human Services identify capitation payments made on behalf of deceased beneficiaries before and after our audit period and repay the Federal share of amounts recovered

We recommend that the Michigan Department of Health and Human Services identify and recover unallowable payments made to managed care entities during our audit period on behalf of deceased beneficiaries, which we estimate to be at least $39,873,514

Ensure that the Senior Federal Law Enforcement Official cadre participates in National Level Exercises, when applicable, and ESF-13 Table Top Exercises.

Develop and implement guidance on how to evaluate air carrier safety risk assessments to ensure the carrier has performed a comprehensive analysis, identified root causes, and established appropriate corrective actions.

Develop and implement inspector guidance on how to evaluate air carrier safety culture and how it should be factored into oversight decisions.