Open Recommendations

We recommend that the State agency enhance the monitoring of provider compliance by conducting periodic reviews of telehealth payments for compliance with requirements.

We recommend that the State agency establish a list of acceptable telehealth procedure codes.

(U) Transfer to the Stagehand program the field division FSL already used by Stagehand or determine an alternative approach that gives Stagehand appropriate control over its staffing to ensure the operational effectiveness, continuity, and security of the Stagehand program.

(U) Work with NSD and other Department stakeholders to develop an integrated system for tracking requests for AGEs and Otherwise Illegal Activity from initiation through final approval that can meet the FBl's and the Department's operational needs, provide visibility about the status of a given request. and identify specific and systemic delays in the AGE and Otherwise Illegal Activity approval process.

(U) Establish reasonable and attainable qualifications for UCCs to better ensure UCCs have appropriate undercover experience, grade level. and adequate time to effectively conduct their undercover-related
duties. Once the UCC qualifications are established, the FBI should update its policies and procedures to reflect the new requirements.

We recommend that Keystone First HealthChoices coordinate with the Pennsylvania Department of Human Services, Office of Medical Assistance Program, to update Keystone First's administrative process to require that medical directors assess whether overnight care requests meet the medical necessity requirement based on the documentation Keystone First has received even if some documentation, such as the caregiver's work verification documentation, is missing.

Review all pediatric skilled nursing service requests for which overnight care was completely denied and determine whether the overnight care requests meet the medical necessity requirement regardless of whether the caregiver provided work or school verification documentation.

Implement a revised initial denial notice to explain that a beneficiary has the right to request a State fair hearing after exhausting the MCO's appeals process.

We recommend that the Pennsylvania Department of Human Services, Office of Medical Assistance Program, revise the initial denial notice template referenced under Exhibit N in the HealthChoices Agreement to include information regarding the beneficiary's right to request a State fair hearing after exhausting the MCO's appeals process.

We recommend that CMS update the HH Pricer logic to check for missing and invalid FIPS codes on all home health claims and work with MACs to ensure that these claims are returned to providers for correction.

We recommend that CMS re-educate providers on the requirement for all home health claims to be submitted with the FIPS code for the county where the service was provided.

We recommend the El Centro Sector Chief, Border Patrol, U.S. Customs andBorder Protection, and Director of Field Operations, San Diego Field Office,Office of Field Operations, U.S. Customs and Border Protection: Conduct refresher training on recording information incustody logs, highlighting the importance of accurately accounting for allactions completed by CBP and contract personnel, such as health interviews,meals, and showers.

Develop and implement a process for revoking access to Bureau systems for separating Bureau employees.

Develop and implement procedures for timely collection of servicing fees and advisor fees in accordance with TIFIA program requirements.

Develop an accurate reporting system to identify and monitor payments not received on the date they are due.

Reimburse the $200,000 advisor fee overpayment referenced in this report.

Develop and implement a uniform policy identifying what documentation borrowers must submit with requisition request and disseminate to Operating Administrations.

CMS should explore the discrepancy between Medicaid claims data and medical documentation for lead toxicity and implement solutions to ensure better oversight of the EPSDT program.

CMS should issue guidance to reiterate State obligations under the EPSDT benefit to ensure access to services to correct or ameliorate confirmed blood lead levels identified during screenings.

Design and implement a quality assurance program to ensure that SBA system hardware inventory is maintained as required by the National Institute of Standards and Technology (NIST) Special Publication 800-53.

Implement a process to ensure SBA reviews its external service providers for supply chain risks and ensure all assessments of supply chain risks are documented as outlined in NIST 800-53.

Communicate and reinforce to program offices the requirement to review and remove system and user accounts in accordance with SOP 90 47 6.

Develop, document, and implement a process that requires management review of information security data and report information security threats.

Coordinate with the Office of General Counsel; Office of Resolution Management, Diversity and Inclusion; and the Department of Justice Civil Rights Division to bring the existing Veterans Benefits Administration’s Adjudication Procedures Manual for accommodating veterans with visual impairments into compliance with38 C.F.R. § 14.500, VA Directive 5975, and Executive Order 12250.

Assign accessibility coordinators, publicize their names, and conduct a self-evaluation of policies as outlined in VA accessibility requirements.