Open Recommendations

We recommend that Regence BlueCross BlueShield of Oregon 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 Regence BlueCross BlueShield of Oregon continue to examine 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.

Thoroughly review each COVID-19 EIDL, grant, and advance application submitted from foreign IP addresses that were approved and funded and verify eligibility. If ineligibility or evidence of potential fraud is found, SBA should stop any further or future disbursements, recover any disbursed funds, and refer fraudulent loans to OIG for investigation.

Examine controls related to foreign IP addresses and ensure these controls are more effective in future disaster processing systems.

We recommend that the New York State Department of Health refund the estimated $84,329,893 to the Federal Government for payments that did not comply with Federal and State requirements.

We recommend that the New York State Department of Health work with the transportation manager to review the payments to transportation providers that may not have complied with Federal and State requirements, resulting in an estimated $112,028,279 in Federal Medicaid reimbursement, and refund to the Federal Government any unallowable amounts.

The FHFA Office of General Counsel’s Designated Agency Ethics Official or Alternate Designated Agency Ethics Official should improve the Agency’s existing internal controls over its employee financial disclosure process by performing and documenting technical reviews and conflict of interest analysis within 60 days of receiving employee financial disclosure reports as required by OGE regulations and FHFA policy.

FHFA should improve existing internal controls over its employee financial disclosure process by ensuring that employees file their financial disclosure reports timely as required by the U.S. Office of Government Ethics regulations and FHFA policy.

Rec. 1.c: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting develop and implement guidance or best practices for agreement personnel to validate that the nontraditional defense contractor participated to a significant extent, as proposed, throughout the duration of the prototype project.

Implement and document in appropriate policy and procedures a process to validate whether minority depository institutions continue to meet the minority depository institution definition.

We recommend that USAID/Pakistan determine the allowability of $2,337,335 in questioned costs (ineligible) as detailed in Findings 4.1.2, 4.2.3, 4.3.1, 4.3.2, 4.3.3, and 4.4.1 on pages 23-30 of the audit report and recover any amount that is unallowable.

The Indian Health Service should develop a strategy for expeditiously deploying a new information system when it is necessary to meet an urgent, mission-critical need. The strategy should define the minimum set of controls out of the total number of required controls that should be addressed and, if applicable tested, before the new system is authorized to operate until it is feasible to address all required controls. The authorization to operate should include an acceptance of risk for not implementing all required controls, specify a date by which the remaining required controls will be implemented and tested, and be replaced…

The Indian Health Service should ensure adequate policies, procedures and training are implemented to ensure that known vulnerabilities that may impact the telehealth technologies are remediated in a timely manner.

Rec. 1: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness update Federal Employees' Compensation Act guidance to clearly establish the Injury Compensation Program Administrator roles and responsibilities, including tracking and recouping overpayments and reviewing the chargeback reports.

Rec. 2.a: The DoD OIG recommended that the Assistant Secretary of the Navy (Manpower and Reserve Affairs) develop and issue formal guidance that provides a consistent approach for implementing the Federal Employees' Compensation Act Program, including assigning staff, completing chargeback reviews, tracking and monitoring overpayments, maintaining claim files in the Defense Injury and Unemployment Compensation System, and referring claims for investigation.

Rec. 2.b: The DoD OIG recommended that the Assistant Secretary of the Navy (Manpower and Reserve Affairs) establish guidance for completing and setting the frequency of command assessments and ensure that those assessments are completed.

Rec. 2.c: The DoD OIG recommended that the Assistant Secretary of the Navy (Manpower and Reserve Affairs) complete a workforce study that identifies the number of Department of the Navy Office of Civilian Human Resources personnel required to perform the Federal Employees' Compensation Act workload, including the required functions of oversight and command assessments.

Rec. 2.d: The DoD OIG recommended that the Assistant Secretary of the Navy (Manpower and Reserve Affairs) include timeframes within updates to Secretary of the Navy Instruction 12810.2A, "Federal Employees' Compensation Act Program" for the Injury Compensation Program Administrators to complete the Injury Compensation Program Administrator Level I course.

Rec. 2.e: The DoD OIG recommended that the Assistant Secretary of the Navy (Manpower and Reserve Affairs) complete a workforce study that identifies the number of Injury Compensation Program Administrators required to implement and perform the Federal Employees' Compensation Act Program workload, including the required functions of case management, chargeback reviews, and long-term claim file reviews, once the Under Secretary of Defense for Personnel and Readiness clearly establishes the Injury Compensation Program Administrator roles and responsibilities.

Rec. 3: The DoD OIG recommended that the Defense Civilian Personnel Advisory Service Director conduct an analysis of the software and databases needed to manage Federal Employees' Compensation Act claims, such as the Social Security Administration's Death Master File, and provide Injury Compensation Program Administrators access as appropriate.

Rec. 4.a: The DoD OIG recommended that the Chief of Naval Operations and the Commandant of the Marine Corps direct the Human Resources Office Directors to ensure the Injury Compensation Program Administrators accomplish the Injury Compensation Program Administrator Level I training as required by Secretary of the Navy Instruction 12810.2A. Once the training is complete, report the information to the Department of the Navy Office of Civilian Human Resources Injury and Unemployment Compensation Program Manager to track the Injury Compensation Program Administrator's compliance with all training related to the Federal Employees' Compensation Act Program and take appropriate action for those…

Rec. 4.b: The DoD OIG recommended that the Chief of Naval Operations and the Commandant of the Marine Corps direct the Human Resources Office Directors to conduct periodic reviews of claim files to ensure that the Injury Compensation Program Administrators are maintaining adequate documentation and elevating documentation requests to Defense Civilian Personnel Advisory Service Advisors when the Department of Labor Office of Workers' Compensation Programs is unresponsive, as required by the Significant Claims Process Standard Operating Procedure.

Rec. 4.c: The DoD OIG recommended that the Chief of Naval Operations and the Commandant of the Marine Corps direct the Human Resources Office Directors to report overpayment information to the Department of the Navy Office of Civilian Human Resources Injury and Unemployment Compensation Program Manager to monitor the outcomes of all Federal Employees' Compensation Act overpayments, once the Under Secretary of Defense for Personnel and Readiness issues the guidance for tracking and recouping overpayments.

We recommend the Secretary of Homeland Security develop a comprehensive contingency plan to support similar emergency situations in the future and account for, screen, vet, and inspect all individuals during unprecedented events when limited biographic data is available. Specifically:
a.
The plan should include, at a minimum, lessons learned from departmental after-action reports that can be incorporated into the plan for future events, lead roles and responsibilities, points of contact, established processes, and expected timeframes.
b.
The policies and procedures should ensure accountability, standard practices, and quality assurance across DHS components involved in screening, vetting, and inspecting individuals in emergency…

Improve policies, procedures, and guidance to clearly define the last major facility life cycle stage and define how NSF will carry out these transitions. These documents should identify steps for managing the transition, for designating and identifying internal resources to facilitate the process, and for obtaining required reviews and approvals.