Open Recommendations

We recommend that the FWS require the Department to implement or revise policies and procedures to ensure leave allocated to a grant code does not exceed the value of leave earned on that grant.

Design and implement a comprehensive migration plan for the COVID-19 EIDL program, to include defined acceptance criteria and robust testing, with detailed project milestones and defined areas of responsibility for program management, information technology, and procurement groups so that data is preserved to meet the needs of all stakeholders.

We recommend that Lahey Clinic, Inc. refund to the MAC $6,015 in overpayments for critical care services.

We recommend that Lahey Clinic, Inc. based on the results of this audit, exercise reasonable diligence to identify, report, and return any overpayments in accordance with the 60-day rule and identify any returned overpayments as having been made in accordance with this recommendation.

We recommend that Cariten Health Plan, Inc. refund to the Federal Government the $9,212,531 of estimated net overpayments.

We recommend that Cariten Health Plan, 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 Cariten Health Plan, Inc. 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.

Provide documentation, or a full and detailed written explanation, of the process Oklahoma used to determine the initiatives it supported with GEER grant funds and the entities it selected to administer the initiatives.

Develop and implement a process to ensure that it documents the criteria and decisions made for awarding future GEER grant funds in accordance with applicable requirements.

Develop and implement internal controls to ensure that it administers current and future GEER grants in accordance with applicable Federal laws and grant requirements, including ensuring that grant subrecipients are provided the proper award documentation; and that any entity that is awarded Federal funds retains records relating to those awards in accordance with Federal requirements.

Perform a 100 percent review, or review a statistical sample, of the Stay in School Fund microgrant recipients to confirm that all students were eligible to receive GEER grant funds.

Develop and implement written policies and procedures to describe the specific circumstances under which deviations from procurement rules are warranted, including procedures about required documentation of such decisions for procurements that do not use competitive bidding but use Federal education funds.

Take appropriate action if the documentation and other information provided by Oklahoma in response to the above recommendations does not support that the State followed applicable requirements.

Return $652,720 to the Department for the unallowable Bridge the Gap expenditures we identified or provide documentation to support that the expenditures were allowable or the items were purchased with personal funds.

Perform a 100-percent review, or review a statistical sample, of the $5,473,894 in Bridge the Gap expenditures that we did not review to determine whether the expenditures were allowable, and if applicable, return the funds for any unallowable expenditures to the Department.

Develop and implement additional internal controls for the Skills to Rebuild, Learn Anywhere Oklahoma, Bridge the Gap, and Stay in School Fund initiatives that include written monitoring procedures for those processes that are already in place, and for additional procedures that include a review of expenditures and supporting documentation, and a review of documentation that supports the information in initiatives’ weekly status reports.

Develop and implement internal controls to ensure that fiscal agents for Federal grant programs obtain an understanding of the rules and regulations surrounding the grant programs they are tasked with overseeing.

Develop and implement controls to ensure that Oklahoma’s State agencies that receive Federal funds have written cash management policies and procedures, including policies for the draw down and disbursement of grant funds in accordance with Federal requirements.

Return to the Department any unexpended GEER grant funds applicable to our audit scope that are being held by GEER grant subrecipients.

Develop and implement internal controls to ensure that fiscal agents for Federal grant programs obtain an understanding of the rules and regulations surrounding the grant programs they are tasked with overseeing.

Require its fiscal agent or State program representative to work closely with the Department to ensure that other GEER grants are administered in compliance with cash management rules and with any actions the Department determines are needed, if warranted.

OIG recommends that U.S. Embassy Freetown, Sierra Leone, review its procurement files, identify those (estimated at approximately 3,800) that should be closed, and closeout the procurement files accordingly.

We recommend the Assistant Secretary for Trade and Economic Security of DHS’ Office of Strategy, Policy, and Plans, in coordination with ICE and CBP, develop, implement, and monitor a departmental strategic, risk-based approach for managing and enforcing intellectual property rights.

We recommend the Executive Assistant Commissioner for CBP Office of Field Operations direct the coordinated establishment and implementation of a national database for recording non-seizure events, such as abandonments and return-to-sender.

We recommend that the Centers for Medicare & Medicaid Services work with State survey agencies to require mandatory participation in standardized life safety training for nursing home staff.