Open Recommendations

We recommend that the Municipality of Barceloneta reinforce existing policies and procedures to ensure that Head Start program bank reconciliations are completed in a timely manner.

We recommend that the Municipality of Barceloneta ensure that criminal background checks on employees and contractors that have direct contact with children are completed within required time frames.

CMS should lower Medicare's payment rates for intermittent urinary catheters.

We recommend that WellCare of Florida, Inc. refund to the Federal Government the $3,518,465 of estimated net overpayments.

We recommend that WellCare of Florida, Inc. identify, for the high-risk diagnoses included in this 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 WellCare of Florida, Inc. continue its examination of 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 take appropriate steps to enable a successful transition from current pandemic-related flexibilities to well-considered longterm policies for the use of telehealth for beneficiaries in urban areas and from the beneficiary's home.

CMS should temporarily extend the use of audio-only telehealth services and evaluate their impact.

CMS should require a modifier to identify all audio-only telehealth services provided in Medicare.

CMS should use telehealth to advance health care equity.

CMS should strengthen monitoring and targeted oversight of telehealth services.

CMS should provide additional education to providers on appropriate billing for telehealth services.

CMS should improve the transparency of "incident to" services when clinical staff primarily delivered a telehealth service.

CMS should identify telehealth companies that bill Medicare.

CMS should follow up on the providers identified in this report.

We recommend that the Montana Department of Public Health and Human Services refund to the Federal Government $5,065,966 (Federal share) in overpayments.

We recommend that the Montana Department of Public Health and Human Services ensure that it always follows its established policies and procedures by: o reviewing TCM providers' case manager hiring practices to verify adherence with the State plan's experience requirements and to ensure that case managers'qualifications were documented, o implementing a process to review billed services to verify that they were allowable and properly documented, and o reviewing target group eligibility documentation to ensure that all individuals receiving services were eligible.

We recommend that the Montana Department of Public Health and Human Services require TCM providers to comply with established policies and procedures in order to ensure that: o case managers who render TCM services to recipients have the experience required by the State plan supplement, o TCM providers maintain documentation to support the TCM services rendered, o TCM providers maintain documentation to support that case managers are qualified to perform TCM services, o the State agency does not pay TCM providers or claim Federal Medicaid reimbursement for services that are not allowable TCM services, and o recipients receiving TCM services…

We recommend that the contracting officer require the Plan to return $607,204 to the FEHBP for the claim overpayments that were written off by the Plan without adequate support and/or justification, whether recovered or not, as diligent efforts to recover were not made.

We recommend that the Director of HUD's Newark Office of Public Housing make a determination regarding outstanding agreement income, including whether those unspent funds should be returned to the public housing agencies, thereby putting up to $697,912 to better use, including $478,165 related to Asbury Park and $219,747 related to Red Bank.

We recommend that the Director of HUD's Newark Office of Public Housing provide technical assistance to Long Branch and require updates to its procedures to ensure that it properly classifies income received under any future agreements or activities.

We recommend that the Director of HUD's Newark Office of Public Housing require Long Branch to prepare and provide support for a reasonable estimate of the amount of employee time used to perform services for Asbury Park and Red Bank and the amount of Long Branch program funds used to pay for that time.

We recommend that the Director of HUD's Newark Office of Public Housing require Long Branch to reimburse Long Branch's program from non-Federal funds for any Long Branch program funds used for payroll expenses related to services provided to Asbury Park and Red Bank as established in recommendation 2A, estimated to be $1,014,660.

We recommend that the Director of HUD's Newark Office of Public Housing require Long Branch to prepare and provide support to show the reasonableness and eligibility of the $1,583,652 in employee incentive payments related to services performed for Asbury Park and Red Bank, which was paid from agreement income, or reimburse its program from non-Federal funds for any amount it cannot support.

We recommend that the Director of HUD's Newark Office of Public Housing require Long Branch to implement adequate controls to ensure compliance with applicable cost principle requirements for employees, including those covering compensation for personal services, such as wages, salaries, and incentive payments, at 2 CFR 200.430. Records should reasonably reflect the total activity for which Long Branch's employees are compensated by the non-Federal entity and support the distribution of compensation among specific activities and cost objectives.