Open Recommendations

Ensures that the Council complies with the procurement and suspension and debarment requirements.

Recommendation 1 - We recommend the State agency refund $180,288 ($118,990 Federal share) for duplicate Title IV-D MPRs.

Recommendation # 5 - We recommend the State agency develop policies and procedures to prevent incorrect rates from being paid and ensure supporting documentation and invoices are reviewed and approved prior to the payment to the court administrator’s office and strengthen internal controls to ensure these invoice-review processes are followed.

Recommendation # 2 - We recommend that the Vermont Office of Child Support refund $48,891 ($32,268 Federal share) for Title IV-D MPRs, which were reimbursed at the incorrect county rate.

Recommendation # 4 - We recommend the State agency work with the court administrator’s office to improve the MPR processing system and establish policies and procedures and application controls to ensure duplicates can be prevented or detected or establish policies and procedures to ensure a manual review of all MPRs is performed .

Recommendation # 6 - We recommend the State agency develop policies and procedures for allocating salaries to the individual family courts which ensures the allocation is supported and accurately reflects the relative benefits received. Specifically: • ensure the courts report their Title IV-D activities each pay period as described within the cooperative agreement, and • ensure the IAG performs its functions as outlined within the cooperative agreement to maintain the key internal control of segregation of key duties by reviewing job positions, employee activity, and interviews managing supervisors and staff to determine the reasonable amount of resources (time and effort)…

Recommendation # 3 - We recommend the State agency work with ACF to determine what portion of the $1,374,320 ($907,051) for unsupported salaries allocated represents Title IV-D eligible costs or refund the entire amount.

Reimburse HUD $30,037 from nonproject funds for the overpayment of housing assistance and utility allowances due to incorrect calculations.

Support or reimburse HUD $159,938 from nonproject funds for the unsupported payments of housing assistance cited in the finding.

Pursue collection from the applicable household or reimburse HUD $26,915 from nonproject funds for the overpayment of housing assistance due to unreported income.

Implement adequate quality control procedures to ensure that housing assistance payments are appropriately calculated and supported. These procedures and controls should ensure that $54,257 in program funds is appropriately used for future payments.

Ensure that the management agent's staff is properly trained and familiar with HUD's and the project's requirements regarding housing assistance payments calculations.

Conduct criminal record background checks in accordance with the project's policies and procedures to ensure that adult members of all households, including the 11 households for which HUD made housing assistance payments totaling $239,500, were eligible to participate in the program. If the participants are deemed ineligible, the owner should follow applicable regulations to terminate or modify assistance and reimburse HUD from nonproject funds for those housing assistance payments deemed ineligible.

ACF’s ORR should develop and implement strategies to assist care provider facilities in overcoming obstacles to hiring and retaining qualified mental health clinicians

ACF’s ORR should identify and disseminate evidence-based approaches to addressing trauma in short-term therapy

ACF’s ORR should assess whether to establish maximum caseloads for individual mental health clinicians

ACF’s ORR should help care provider facilities improve their access to mental health specialists

ACF’s ORR should take all reasonable steps to minimize the time that children remain in ORR custody.

Continue to work with the Labor Relations department to identify opportunities to increase staffing flexibility among agreement employees, especially as the company develops maintenance strategies for the new equipment it is purchasing.

We recommend that the State agency bill for and collect from manufacturers rebates for single-source and top-20 multiple-source pharmacy and physician-administered drugs and refund to the Federal Government the estimated $28,103,346 (Federal share).

We recommend the State agency work with CMS to determine whether the other pharmacy and physician-administered drugs were eligible for rebates and, if so, upon receipt of the rebates, refund up to an estimated $47,426,944 (Federal share) our audit period and $119,561,574 (Federal share) for the nearly 4-year period before our audit period.

We recommend that the State agency ensure that all pharmacy and physician-administered drugs eligible for rebates are processed for rebates.

We recommend that the State agency develop and implement written policies and procedures for its drug rebate program.

We recommend that the State agency strengthen its NDC edit (implemented on January 1, 2015), to ensure that NDCs are captured for all drug utilization data.