Open Recommendations

We recommend that the Grantee develop and implement formal written policies and procedures surrounding the management of Federal awards, in accordance with the Uniform Guidance.

We recommend that the contracting officer work with the Association to implement modifications to EOB messaging in situations where member liability changes because of a claim adjustment to ensure that members are clearly notified of the changes in their liability.

We recommend that the contracting officer direct the Association to review all 4,805 claims identified by our review as potential overcharges and to return all amounts determined to be overpaid by the FEHBP unless it can demonstrate that it made a prompt and diligent effort to recover the overpayments as per contract CS 1039. Additionally, we recommend that the contracting officer direct the Association to submit periodic reports to it on the progress of the review and recovery efforts.

We recommend that the contracting officer disallow $83,565 in overcharges and direct the Association to return the funds to the FEHBP. To date, $60,392 has been recovered and $23,173 remains due to the FEHBP.

We recommend the contracting officer direct the Association to require the Plan to provide thorough retraining to its processors on the proper procedures of recognizing and processing surprise billing claims.

We recommend that the contracting officer allow $1,110 in undercharges to the FEHBP. To date, $728 in additional payments have been made and $382 remains due to providers.

We recommend that the contracting officer ensure that the Association completes and implements the system enhancement to recognize all claim lines with the claim level surprise billing code edit.

We recommend that the contracting officer direct the Association to require the Plan to implement controls to prevent processors from overriding edit codes requiring a completed medical review and to verify when this corrective action has been completed.

We recommend the contracting officer direct the Association to update its Benefit Policy Manual instructions to plans to require them to use the official guidance in the FAM Chapter 19a to determine eligibility for surprise billing protections and not the member portal.

We recommend that the contracting officer disallow $22,317 in overcharges and direct the Association to return the funds to the FEHBP. To date, the Plan has recovered $15,118, and $7,199 remains due to the FEHBP.

We recommend that the contracting officer direct the Association to identify all non-covered procedure codes that do not contain the proper business rule configurations for both facility and professional claims and to make those changes to its system.

We recommend that the contracting officer direct the Association to implement policies and procedures to update FEPDirect with all required business rules and configuration updates needed whenever changes are made to the FAM Exhibit 2, to ensure that non-covered benefits are not charged to the FEHBP.

We recommend that the contracting officer direct the Association to ensure that the Plan institutes policies and procedures to safeguard and have ready at hand all documentation related to provider contracts that support both the contract and pricing arrangements between it and the provider.

We recommend the Vice President, Chief Information and Digital Officer, Information Technology, implement, assess, and maintain common secure configuration settings for all information systems.

We recommend the Vice President, Chief Information and Digital Officer, Information Technology, incorporate vulnerability scanning into the Continuous Diagnostics and Mitigation dashboard in accordance with Binding Operational Directive 23-01, in coordination with Department of Homeland Security as necessary.

We recommend the Vice President, Chief Information and Digital Officer, Information Technology, refine the profiles periodically based on known risk exposure and residual risk, align cybersecurity profiles with risk strategy, and periodically monitor and report on progress in reaching TVA’s target profile.

We recommend the Vice President, Chief Information and Digital Officer, Information Technology, verify the data and corresponding metadata in the data inventories are subject to the monitoring processes defined within TVA’s Information Security Continuous Monitoring strategy.

The facility Director ensures staff review primary care panel sizes and capacity levels to ensure they are accurate.

The facility Director ensures staff review primary care panel sizes and capacity levels to ensure they are accurate.

Strengthen oversight to prevent and identify split purchases.

Develop stronger purchase card controls over donated funds to prevent improper purchases.

NSF review the details of the split purchases to determine whether the violations were a
result of a lack of knowledge/misunderstanding or intentional misconduct; and that NSF
address the root cause appropriately.

(U) Rec. 1: The DoD OIG recommended that the Secretary of the Army update Army Regulation 190-45 and Army Executive Order 222-17 to require commanders to report threats of violence against civilians and non-Government facilities, or activities by Service members, dependents, or civilian employees to the Services Senior leadership though the operations center.

(U) Rec. 2: The DoD OIG recommended that the Secretary of the Navy update Office of the Chief of Naval Operations Instruction 3100.6K and the Approved Consolidated Chief of Naval Operations and Secretary of the Navy Commanders Critical Incident Report to require commanders to report threats of violence against civilians and non-Government, or activities by Service members, dependents, or civilian employees to the Services senior leadership through the operations center.

(U) Rec. 4: The DoD OIG recommended that the Director, Department of the Army Criminal Investigation Division review the installation law enforcement investigations that we identified that were not reported to the Department of the Army Criminal Investigation Division and conduct any additional investigative actions they deem appropriate.