Open Recommendations

Upon the completion of the risk analysis noted above, management should develop and implement procedures that ensure PMS users do not have sufficient access to allow the unmonitored execution of incompatible transactions.

We recommend that the Office of Programs submit a plan, within 90 days, to the Senate Committee on Homeland Security and Governmental Affairs, the House Committee on Oversight and Government Reform, and the Office of Management and Budget, describing the actions that the agency will take to become compliant.

We recommend that the Office of Programs achieve a gross improper payment rate of less than 10 percent for Railroad Medicare. The Office of Programs through the Railroad Retirement Board’s Specialty Medicare Administrative Contractor should continue to work with Medicare providers to communicate the documentation requirements and monitor the adherence to such requirements throughout the year.

We recommend that the Office of Programs obtain and maintain the applicable Railroad Medicare sampling and estimation plan agency certification. It must be a Centers for Medicare and Medicaid Services’ certification, Railroad Retirement Board Chief Financial Officer’s certification, or other Railroad Retirement Board program official’s certification.

We recommend that the Office of Programs obtain the Railroad Medicare sampling and estimation plan for the fiscal year 2019 payment integrity reporting cycle.

We recommend that the Office of Programs establish a written policy to ensure subsequent Railroad Medicare sampling and estimation plans are obtained and readily available for review so that a qualified statistician would be able to replicate what was done or so that Office of Management and Budget, agency Inspector General, or Government Accountability Office personnel can evaluate the design.

We recommend that the Office of Programs submit the Railroad Medicare sampling and estimation plan for fiscal year 2019 to the Office of Management and Budget by the June 30th deadline.

We recommend that the Office of Programs obtain the Office of Management and Budget approval for Railroad Medicare’s overall reduction target rate.

We recommend that the Office of Programs and the Office of Administration work together to update the Memorandum of Understanding (MOU13-61) to describe the applicable agency responsibilities as they pertain to Improper Payments Elimination and Recovery Act laws and Office of Management and Budget guidance for payment integrity reporting.

We recommend that the Office of Programs include a brief narrative of the reduction in improper payments that is attributable to the Do Not Pay Initiative for Railroad Medicare and associated systems.

We recommend that the Office of Programs identify, publish, and provide a justification for Railroad Medicare uncollectible amounts.

We recommend that the Office of Programs adopt the Office of Management and Budget’s recommended best practice and describe statutory or regulatory barriers in the fiscal year 2019 Performance and Accountability Report.

We recommend that the Office of Programs update applicable performance appraisals with specific criteria for meeting applicable improper payment reduction targets and establish and maintain sufficient internal controls to reduce improper payments in accordance with Office of Management and Budget Circular A 136.

We recommend that the Office of Programs develop and implement an internal control process (e.g. a checklist) to ensure all updates to Appendix C and Office of Management and Budget Circular A 136 relating to improper payments are sufficiently addressed for payment integrity reporting.

We recommend that the Office of Programs work with the Centers for Medicare and Medicaid Services to meet the needs of Railroad Retirement Board’s payment integrity reporting. If the Railroad Retirement Board is not able to obtain claims data that coincides with the fiscal year being reported, obtain Office of Management and Budget’s approval for the delayed reporting timeframe.

We recommend that the Office of Programs and the Office of Administration work together to update the Memorandum of Understanding (MOU13-61) dated April 12, 2013 to ensure it reflects the applicable agency responsibilities as they pertain to improper payment reporting sampling and estimation plans.

We recommend that the Bureau of Fiscal Operations develop a payment recapture audit program for vendor and employee payments, or approved alternative method, if one is deemed cost effective.

We recommend that the Bureau of Fiscal Operations, if a payment recapture audit program is deemed not cost effective, provide a cost benefit analysis, in accordance with the Office of Management and Budget's best practices as outlined in Appendix C, in writing to Office of Management and Budget and the Office of Inspector General, and include it in the fiscal year 2019 Performance and Accountability Report.

Require that SGC provide Sanctuary with the requirements of an adequate financial management system and ensure that Sanctuary implements an adequate system. The documentation provided should include guidance on how to determine the allowability of grant costs claimed and accounting for both Federal and match costs.

Require Serve Guam Commission to submit an updated Financial Federal Report for the 14AH award that removes the $18,761 of questioned match costs.

Require SGC, as part of its subgrantee monitoring processes, to perform periodic testing of subgrantees’ other direct costs to ensure that they incurred and claimed all costs in accordance with grant provisions, laws, and regulations.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to support the appraised fair market values of the 14 properties sampled to ensure that $5,920,097 in settlement costs was supported. This recommendation includes but is not limited to providing support to show that appraisals contained accurate and verified information for the subject and comparable properties, time adjustments were supported, and other adjustments were supported.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to support the appraised fair market values of the 942 other properties included in our sampling universe to ensure that $361,465,173 in settlement costs was supported. This recommendation includes but is not limited to providing support to show that appraisals contained accurate and verified information for the subject and comparable properties, time adjustments were supported, and other adjustments were supported.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to strengthen controls over the property valuation process for its program to ensure that up to $93,350,616 not yet disbursed is put to better use.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to show that $3,119,209 paid for appraisals and poststorm addenda performed by its contractor was reasonable, supported, and for services that were performed in accordance with applicable requirements or reimburse any unsupported costs from non-Federal funds.