Open Recommendations

The Centers for Medicare & Medicaid Services should educate providers on documentation and time requirements for ACP services to comply with Federal requirements. (That is, when another service is performed concurrently with a time-based service, the time associated with the concurrent service should not be included in the time used for reporting the time-based service, and time and ACP discussion must be documented). Had the requirements been followed, Medicare could have saved an estimated $42,266,931 during our audit period.

The Centers for Medicare & Medicaid Services should instruct the MACs to recoup $33,332 for ACP services paid in error for claims in our sample.

The Centers for Medicare & Medicaid Services should instruct the MACs, based on the results of this audit, to notify appropriate providers (i.e., those for whom CMS determines that this audit constitutes credible information of potential overpayments) so that the providers can exercise reasonable diligence in identifying, reporting, and returning any overpayments in accordance with the 60-day rule and identify any of those returned overpayments as having been made in accordance with this recommendation.

The Centers for Medicare & Medicaid Services should establish Medicare requirements that address when it is appropriate to provide multiple ACP services for a single beneficiary and how these services should be documented when required to support the need for multiple services.

Complete a detailed performance diagnostic and gap analysis on AmeriCorps’ financial management personnel, processes, and systems, including a root cause analysis, and then develop, design, and implement a plan toward short- and long-term executable goals.

Perform intermediate assessments of the effectiveness of its executed plans and final evaluations of its financial management operations to ensure desired results are achieved.

Require each department head to be responsible and accountable for timely developing and implementing CAPs and require each department’s staff to test the design and effectiveness of each CAP as implemented to ensure that it achieves the desired results.

Develop and implement effective controls, including a quality assurance process, necessary to ensure that: (a) accounting and reporting are in accordance with U.S. GAAP and financial information is presented in compliance with OMB Circular A-136. (b) account balances are accurate as of and through the reporting period. (c) the proper validation, review, and approval over financial reporting and the AMR compilation.

Develop, identify and make available the training necessary to ensure that staff obtain and update the skills necessary to ensure compliance with: (a) FASAB concept and accounting standards. (b) OMB A-123. (c) OMB A-136. (d) GAO Disclosure checklist. (e) Treasury’s U.S. Standard General Ledger annual update. (f) the correct use of the Business Event Transaction Codes (BETC) when submitting transactions to Treasury.

Develop and implement financial reporting internal controls to analyze and address the root causes of the need for journal entries and the corrective actions in financial management systems to reduce the necessity of future journal entries.

Determine the root cause behind the differences noted in the UDO balance derived from the procurement documents and the expenditures and the recorded GL amount and take the appropriate steps in resolving the reason behind the variances that are occurring.

Strengthen controls to ensure proper authorization signatures on all contracts and amendments that require bi-lateral signatures for the proper execution of the award.

Develop and implement its Accounts Payable (AP) accrual methodology and perform tests of design and effectiveness over its UDO and AP accrual process.

Verify and validate the underlying input data to the TOLM.

After the verification and validation, reassess its assumptions and consider expanding the subjective elements of the calculation (i.e., those based on changes to the economy and the job market) to include changes in the way awards are utilized.

Establish a requirement for the Office of Grant Administration (OGA) or an appropriate AmeriCorps official to prepare a summary report, as part of the closeout process, verifying all required grantee information has been received and accepted, and the recovery amount reconciles to the underlying support (e.g., Notice of Grant Award for de-obligation, Final Federal Financial Report, Payment Management Services, etc.).

Develop and implement financial reporting internal controls to analyze and address the root causes of the reconciliation errors.

Revamp the grant accrual processes to include internal controls such as reconciliations, calculation documentation, quality control reviews, and basis for the accrual methodologies to mitigate the risk of error. (Modified Repeat)

Provide training to all personnel involved in the grant processing to ensure proper classification of funds in the Oracle system and ensure timely resolution of the variances between identified between the Momentum, Oracle, and PMS systems.

Develop standard operating procedures to ensure all balances recorded in the Reimbursable Analysis are supported by underlying source documentation (e.g., invoices).

Assess the training necessary to ensure advance liquidations are properly maintained, documented, and are readily available for examination.

Require each department head to be responsible and accountable for timely developing and implementing CAPs and require each department’s staff to test the design and effectiveness of each CAP as implemented to ensure that it achieves the desired results.

Develop and implement effective controls, including a quality assurance process, necessary to ensure that: (a) accounting and reporting are in accordance with U.S. GAAP and financial information is presented in compliance with OMB A-136. (b) account balances are accurate as of and through the reporting period. (c) the proper validation, review, and approval over financial reporting and the AMR compilation.

Develop, identify and make available the training necessary to ensure that staff obtain and update the skills necessary to ensure compliance with: (a) FASAB concept and accounting standards. (b) OMB A-123. (c) OMB A-136. (d) GAO Disclosure checklist. (e) Treasury’s U.S. Standard General Ledger annual update. (f) the correct use of the Business Event Transaction Codes (BETC) when submitting transactions to Treasury.

Complete a detailed performance diagnostic and gap analysis on AmeriCorps’ financial management personnel, processes, and systems, including a root cause analysis, and then develop, design, and implement a plan toward short- and long-term goals.