Open Recommendations

Incorporate the Environmental Manager into the planning phase of all Capital Investments to ensure potential environmental impacts are addressed.

CMS should Work with States on actions to identify and address MCOs that may be issuing inappropriate prior authorization denials.

CMS should Issue guidance to States on the use of MCO prior authorization data for oversight.

CMS should Require States to review the appropriateness of a sample of MCO prior authorization denials regularly.

CMS should Require States to implement automatic external medical reviews of upheld MCO prior authorization denials.

CMS should Require States to collect data on MCO prior authorization decisions.

Conduct a comprehensive study to identify how the company can support the development and use of more detailed and standardized work breakdown structures in accordance with common industry practices. At minimum, this analysis should determine the following for the Capital Delivery department:a. how many levels of cost detail project managers need to effectively track and manage costs for a diverse capital portfoliob. the extent to which projects or programs should have work breakdown structures with standardized cost elementsc. based on the above decisions, the people, systems, and processes necessary to develop more detailed and standardized work breakdown structures and sustain…

Based on the results of the study, develop a proposal specifying the people, processes, and systems needed to implement more detailed and standardized work breakdown structures and submit it to the Executive Leadership Team for consideration.

We recommend that the BIE ensure that Chemawa Indian School enters into fundraising agreements with any non-Federal entities that solicit donations on behalf of the school.

We recommend that the BIE resolve the $593,367 in questioned costs related to the inappropriate purchases.

We recommend that the BIE develop and implement Budget and Finance policies and procedures that set forth requirements and approval processes for establishing new academic or extracurricular programs.

We recommend that the BIE develop and implement Budget and Finance policies and procedures that provide guidance regarding purchases that can be made with the different funding sources provided to the schools, including Title I funds.

We recommend that the BIE develop and implement Budget and Finance policies and procedures for approving purchase requests, including ensuring the appropriate officials certify that purchases are allowable and reasonable.

We recommend that the BIE develop and provide training to Chemawa Indian School on the newly established Budget and Finance policies and procedures for establishing new academic or extracurricular programs, defining types of purchases that can be made with the different funding sources, and approving purchase requests.

We recommend that the Assistant Secretary - Indian Affairs develop documented procedures for following protocols when constructing new facilities and for making operations and maintenance purchases of more than $2,500.

We recommend that the BIE locate or develop lease agreements with businesses using Chemawa Indian School land.

We recommend that the BIE verify that past and current lease payments are paid in accordance with the terms of the lease agreements.

We recommend that the BIE develop and disseminate policies and procedures to BIE-operated schools for establishing, managing, and overseeing leases that include, at a minimum, requirements and provisions outlined in 25 C.F.R. part 48, defined roles and responsibilities, and requirements for validating that lease payments are paid in accordance with the lease agreements.

We recommend that the BIE require Chemawa Indian School to establish a mechanism to track the location of all accountable system-controlled property.

We recommend that the BIE conduct periodic unannounced, onsite reviews at Chemawa Indian School to monitor the ongoing inventory process and verify the accuracy andcompleteness of the Indian Affairs Financial and Business Management System inventory in keeping with Indian Affairs policy.

We recommend that the BIE develop and provide training for Chemawa Indian School personnel on Indian Affairs Manual part 23 to ensure that Chemawa maintains an inventory of and tags nonexpendable property under $5,000 and to ensure understanding of requirements for expendable property tagging and recordkeeping.

We recommend that the Florida Department of Children and Families provide training to CPIs and caseworkers on medication management and administration that addresses requirements for updating case records in FSFN for children who are prescribed psychotropic medications (including related medication logs and authorizations) and opioid medications.

We recommend that the Florida Department of Children and Families coordinate with the Florida Agency for Health Care Administration to obtain access to Medicaid claim data for all children under its care and supervision.

We recommend that HAM ensure [redacted].

We recommend that HAM ensure [redacted]. Note - this recommendation cannot be implemented until the controls from Recommendation 7 are in place.