Open Recommendations

We recommend the FEMA Deputy Administrator develop a risk-based process for reviewing documentation that supports mission assignment expenditures and apply this process to COVID-19 mission assignments to ensure eligibility of claimed costs.

We recommend the Federal Emergency Management Agency Region II Administrator establish internal controls to ensure properseparation of duties related to the review, approval, and disbursement of Disaster Case Management Program funds to prevent potential fraud, waste, and abuse.

We recommend the Federal Emergency Management Agency Administrator establish policies and procedures for the Disaster CaseManagement Program when the program is not awarded to the State or Territory. The policies should address how FEMA will perform oversight and monitoring and how FEMA will ensure that standards for financial management systems and compliance with the Uniform AdministrativeRequirements, Cost Principles and Audit Requirements for Federal Awards (2C.F.R. Pt. 200) are met.

We recommend the Federal Emergency Management Agency Region II Administrator review all documentation supporting the $65million Disaster Case Management Program reimbursements to the Providers and ensure the documentation is adequate and in accordance with 2 C.F.R. § 200.302(b)(3), 200.400(d), and 200.403(g).

We recommend the Under Secretary for the Office of Strategy, Policy, and Plans: Develop and implement DHS-specific guidance on lines of authority for future UCGs formed for events requiring government-widecoordination.

Update the additionality guidelines and checklist to: a) explicitly state the minimum documentation requirements for establishing additionality whether that be source documentation or contemporaneous memos with the required elements of source, timing, and context

We recommend that the BIE work with the Turtle Mountain Band of Chippewa Indians to resolve the questioned costs of $216,878.

We recommend that the BIE require the Turtle Mountain Band of Chippewa Indians to develop and implement internal controls that will ensure administrative costs claimed support school operations.

Use the fraud risk inventory to enhance program-specific fraud risk assessments for the TBRA and Operating Fund programs.

Use the fraud risk inventory to enhance program-specific fraud risk assessments for the HOME program.

Implement a policy identifying criteria for the inclusion of a service within the Working Capital Fund (WCF); once the criteria are formalized, JMD should evaluate and ensure that the services currently included in the WCF are appropriate, meet the documented criteria, and are clearly presented to the WCF Board for discussion of any necessary changes.

Review the Office of the Chief Information Officer's (OCIO) cost allocation methodology and update as necessary to ensure that component cost allocations are sensible, equitable, and commensurate with benefits of the services provided.

Update its policy to include specific criteria for identifying "basic activities" appropriate to be included in a Rate Memo and reevaluate OCIO's Rate Memos to ensure that the selected services reflect a consistent approach and "basic activities."

Implement a formal process for the CIO Council and WCF Board of Directors to coordinate to improve collaboration and information sharing about the financial and service provision aspects of implementing IT initiatives.

Evaluate procedures for providing components with their expected charges to ensure that components have sufficient information to evaluate the use and associated costs for IT services, as well as enough time to provide feedback and obtain support for any discrepancies.

Evaluate processes to ensure that JMD and OCIO meet the intended requirements of the WCF Handbook, including the implementation of the annual WCF Customer Survey and the development of a comprehensive IT Service Catalog.

Evaluate the administrative operations of OCIO, as well as the information and outcomes of the working groups to enhance the financial management structure and access to clear and complete WCF IT service information.

Review the 20 loans identified in this report as ineligible for the COVID-19 EIDL that the applicants received and recover approximately $2 million improperly disbursed to the applicants.

Review the COVID-19 EIDL disbursements with suspect Taxpayer Identification Numbers made after December 27, 2020 to determine if the loan files contain conclusive evidence that the applicant business existed on January 31, 2020, and therefore, met the CARES Act eligibility requirements. If not, flag the borrower as ineligible and recover the funds.

We recommend that Highmark Senior Health Company refund to the Federal Government the $6,227,005 of estimated net overpayments;

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

We recommend that Highmark continue its examination of its existing compliance procedures to identify areas where improvements can be made to ensure 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.

Refund to the Federal Government the $7,784,540 of estimated overpayments

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

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.