Open Recommendations

We recommend the ICE Head of Contracting Activity:direct procurement and program staff to review the qualifications for skillsets, education, and work experience of all Capgemini Government Solutions, LLC employees currently working on the contract and removeunqualified staff; andx ensure the contracting officer representative reviews all invoices paid toCapgemini Government Solutions, LLC between August 2018 andDecember 2019. The review should highlight any cost for labor notprovided and determine any amounts to recover.

The Department should modify existing policy concerning a DOJ attorney's participation in a criminal or civil investigation or prosecution in which a former client is a witness, subject, target, defendant, or party, to ensure that any such participation does not cause a reasonable person to question that attorney's impartiality.

The Department should consider what requirements, guidance, and/or training should be provided to any incoming Department attorneys entering service regarding their handling of potential conflicts arising from their representation of clients arising from their representation of clients prior to joining DOJ.

Perform and update the Supplemental Nutrition Assistance Program (SNAP) Online Purchasing Pilot risk assessment to reflect how Food and Nutrition Service (FNS) will mitigate and test potential risks.

Establish a policy to periodically perform assessments to identify any new risks and re-evaluate existing ones related to the SNAP Online Purchasing Pilot.

We recommend that CGS work with CMS to ensure that its final settlement of contract costs reflects a decrease in Medicare Excess Plan costs of $29,022 for CYs 2015 and 2016.

We recommend the Associate Director for Immigration Records and IdentityServices, U.S. Citizenship and Immigration Services: Collaborate with individual states and/or the NationalLaw Enforcement Telecommunications System to determine whether USCIScan obtain driver’s license photos for E-Verify’s photo matching.

We recommend the Associate Director for Immigration Records and IdentityServices, U.S. Citizenship and Immigration Services: Validate the accuracy of E-Verify’s current workloadprojections and update the projections as needed.

We recommend the Associate Director for Immigration Records and IdentityServices, U.S. Citizenship and Immigration Services: Conduct a study to determine the appropriate resourcesneeded to fully test the E-Verify system’s current and projected workloadcapabilities.

The Office of the Science and Technology Adviser to the Secretary, in coordination with the Offices of the Under Secretary for Economic Growth, Energy, and the Environment, the Deputy Secretary of State, and the Deputy Secretary of State for Management and Resources, should submit a statement of its policy areas of responsibilities in accordance with Department standards.

The Under Secretary for Health coordinates with VA to review the roles, responsibilities, and number of staff required for the VA and Veterans Health Administration offices involved in the development, validation, and implementation of staffing models, and ensure that staffing model-related efforts are prioritized and supported.

The Under Secretary for Health coordinates with VA to evaluate the status of, and provide a timeline for, the development, validation, and implementation of Veterans Health Administration staffing models for all occupations.

The Under Secretary for Health coordinates with VA to evaluate the status of, and provide a timeline for, the implementation of HR Smart-related requirements referenced in VA and Veterans Health Administration policy, with a specific focus on the authorizations, vacancies, budgeted positions, and unbudgeted requirements at the facility, Veterans Integrated Service Network, and national levels.

We recommend that Catholic Home Care strengthen its procedures to ensure that beneficiaries are receiving only reasonable and necessary skilled and dependent services

1. We recommend that Jewish Hospital refund to the Medicare contractor $13,486,524 in estimated overpayments for the audit period for claims that it incorrectly billed that are within the 4-year claim reopening period.

We recommend that Jewish Hospital 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 of those returned overpayments as having been made in accordance with this recommendation.

We recommend that Jewish Hospital strengthen internal controls by: strengthening procedures to verify that all IRF beneficiaries meet Medicare criteria for acute inpatient rehabilitation, developing processes to ensure that procedure and diagnosis codes are supported in the medical records, providing additional training to inpatient and outpatient coding staff on the use of bypass modifiers, and developing procedures to verify that the use of bypass modifiers is supported in the medical records.

Analyze and document the justification for the FAA Contract Tower (FCT) Program's minimum staffing requirements.

Develop and implement an internal process to periodically review, and maintain supporting records for FCT controller staffing minimums.

Develop and implement an internal process"including roles and responsibilities, timeframes, and criteria"to ensure contract requirements are met, and overpayments made to contractors are recovered.

Repay Federal matching funds spent on the case that was ineligible for Federal funding.

Update the FEMA Recovery Standard OperatingProcedure, SOP 9570.24 – Strategic Funds Management – ImplementationProcedures for the Public Assistance Program, at a minimum, to: provide criteria for documentation required for subreceipients’drawdown schedule for funding projections to determine whether fundsare needed within 180 days; and require Regions document the basis for decisions and maintain supportfor these decisions in Grants Manager and in Emergency ManagementMission Integrated Environment (EMMIE).

Develop a mechanism to ensure that the Office ofResponse and Recovery monitors the implementation of the Strategic FundsManagement Initiative in accordance with policy

Finalize the Grant Operations policies and procedures to reflect the current state and post‐reorganization.

Update the testing of design and effectiveness attributes to be consistent with the new policies and procedures.