Open Recommendations

We recommend that the BIA review the Omaha Tribe's revised policy regarding the custody of checks and document that proper controls have been implemented.

We recommend that the BIA resolve the questioned costs of $42,067 by requiring the Omaha Tribe to provide a detailed list of the questioned transactions and voided checks to the BIA for its files to ensure these transactions are not claimed for reimbursement.

We recommend that the BIA resolve the questioned costs of $10,792 by requiring the Omaha Tribe to reallocate these costs to the appropriate funding source.

We recommend that the BIA require the Omaha Tribe to revise its policy to ensure a complete property record for CARES Act-funded assets in accordance with 2 C.F.R. 200.313(d)(1).

Ensure that the IRS does not burden taxpayers in existing payment agreements when PCA contracts are ending by developing a solution to continue to service taxpayers in active payment arrangements.

We recommend that Cigna-HealthSpring of Tennessee, Inc. refund to the Federal Government the $5,987,509 of estimated overpayments.

We recommend that Cigna-HealthSpring of Tennessee, Inc. identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before and after our audit period and refund any resulting overpayments to the Federal Government.

We recommend that Cigna-HealthSpring of Tennessee, Inc. continue its examination of 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.

CMS should build a strategy to strengthen its internal controls for ensuring the accuracy of Part B drug payments.

CMS should actively review current guidance related to the areas identified in this report and determine whether additional guidance would ensure more accurate and consistent ASP calculations.

We recommend the Office of the Secretary establish aDHS oversight entity to ensure National Instant Criminal Background CheckSystem compliance in DHS, which should include:a. coordinating with the Attorney General to resolve open dispositions thatno longer have available information and discontinue use ofadministrative closure dispositions; andb. developing a risk-based strategy for components to assess missingcriminal history records and submit missing dispositions.

We recommend the DHS Office of the Secretary establisha mechanism to track and ensure timely responses to NICS inquiries anddevelop and implement a process to include immigration status at the time ofinquiry for immigration-related inquiries.

We recommend the United States Coast Guard,Assistant Commandant for Human Resources, establish a process for thePersonnel Service Center to notify the Coast Guard Investigative Service of thecompletion of dishonorable discharges and that CGIS personnel enter theminto NICS data.

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

Work with ACF to develop a viable plan for refunding $153,052 in unallowable costs to the Federal Government.

Develop and implement procurement policies and procedures to avoid acquiring unnecessary items and to perform analyses to determine the most reasonable approach for future vehicle purchases.

Develop and implement written policies and procedures to ensure that criminal background checks on employees are completed within required time frames.

We recommend that the State agency refund up to $9,832 to the Federal Government.

We recommend that the State agency enhance the monitoring of provider compliance by conducting periodic reviews of telehealth payments for compliance with requirements.

We recommend that the State agency establish a list of acceptable telehealth procedure codes.

(U) Transfer to the Stagehand program the field division FSL already used by Stagehand or determine an alternative approach that gives Stagehand appropriate control over its staffing to ensure the operational effectiveness, continuity, and security of the Stagehand program.

(U) Work with NSD and other Department stakeholders to develop an integrated system for tracking requests for AGEs and Otherwise Illegal Activity from initiation through final approval that can meet the FBl's and the Department's operational needs, provide visibility about the status of a given request. and identify specific and systemic delays in the AGE and Otherwise Illegal Activity approval process.

(U) Establish reasonable and attainable qualifications for UCCs to better ensure UCCs have appropriate undercover experience, grade level. and adequate time to effectively conduct their undercover-related
duties. Once the UCC qualifications are established, the FBI should update its policies and procedures to reflect the new requirements

We recommend that Keystone First HealthChoices coordinate with the Pennsylvania Department of Human Services, Office of Medical Assistance Program, to update Keystone First's administrative process to require that medical directors assess whether overnight care requests meet the medical necessity requirement based on the documentation Keystone First has received even if some documentation, such as the caregiver's work verification documentation, is missing.