Open Recommendations

We recommend that the University of Michigan Health System implement policies and procedures to ensure that Medicare claims for polysomnography services comply with Medicare requirements.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide its plan to continuously monitor Harris County's pace and performance in its remaining Hurricane Harvey CDBG-DR program and take appropriate action to ensure that program goals are met.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to set performance and financial milestones, including approval of Harris County's projects and obligation and expenditure of funds, for all programs and activities funded under the Harris County subrecipient agreement through the remainder of the contract and deadlines for Harris County to achieve those milestones.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to provide evidence of subrecipient monitoring of Harris County's capacity to manage its Hurricane Harvey grant funds to address duplicative, inefficient, and cost-prohibitive processes or positions. The evidence should include any corrective actions that have been imposed and Harris County's response.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to ensure that Harris County obtains adequate training for its program staff and that the staff continuously demonstrates their understanding of and competence to operate Harris County's programs within applicable requirements. This would include ensuring that Harris County takes appropriate steps to remedy situations where staff are not operating the program within applicable requirements.

We recommend that the Director of the Office of Block Grant Assistance require the Texas GLO to review Harris County's Housing Reimbursement Program policies, including assistance prioritization, to ensure compliance with the Texas GLO's action plan and amendments. This would include the Texas GLO analyzing the County's project pipeline to determine whether changes are warranted to ensure that those most in need are prioritized to receive limited Federal assistance.

Examine ways to implement the use of secure, internal network connections to transfer data between LIMS and other work systems with the goal of implementing a more secure method of data transfer than relying on external storage devices.

We recommend that the New Mexico Human Services Department bill for and collect manufacturers' rebates for the 44,790 claim lines related to single-source and top-20 multiple-source physician-administered drugs that we calculated to be at least $1,239,130 ($900,971 Federal share) and refund the Federal share of rebates collected.

We recommend that the New Mexico Human Services Department work with CMS to determine whether the 25,341 claim lines related to non-top-20 multiple-source physician-administered drugs that we calculated to be at least $226,644 ($164,793 Federal share) were eligible for rebates and, if so, determine the rebates due and, upon receipt of the rebates, refund the Federal share of the rebates collected.

We recommend that the New Mexico Human Services Department work with CMS to determine whether the other physician-administered drugs, associated with 183,859 claim lines and rebates of at least $170,674 ($124,097 Federal share), were eligible for rebates and, if so, determine the rebates due and, upon receipt of the rebates, refund the Federal share of the rebates collected.

We recommend that the New Mexico Human Services Department strengthen internal controls to ensure that all eligible physician-administered drugs are billed for rebate.

We recommend that the New Mexico Human Services Department ensure that all pharmacy and physician-administered drugs eligible for rebates after our audit period are processed for rebates.

Continue to work with states to develop, operate, and maintain a modular set of technological capabilities to modernize the delivery of UI benefits that is sufficient to manage and process sudden spikes in claims volume during emergencies or high unemployment.

Assist states with claims, overpayment, and fraud reporting to create clear and accurate information. Then use the overpayment and fraud reporting to prioritize and assist states with fraud detection and recovery.

Finalize its decision on updating its administrative finality policy and execute an action plan with specific milestones to ensure any updates are implemented timely.

We recommend that Caretenders 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 returned overpayments as having been made in accordance with this recommendation.

We recommend that Caretenders strengthen its procedures to ensure that the homebound status of Medicare beneficiaries is verified and continually monitored and the specific factors qualifying beneficiaries as homebound are documented; beneficiaries are receiving only reasonable and necessary skilled services; and HIPPS codes are billed correctly.

We recommend that Gateway refund $932,607 claimed in unallowable costs related to: (1) indirect costs ($356,121), (2) credits received from vendors ($338,363), (3) equipment that was not purchased in accordance with Federal open competition procurement regulations ($208,600), and (4) use of company vehicles ($29,523). Specifically, Gateway did not adjust its indirect costs claimed based on its provisional rate to reflect its final rate. As a result, Gateway claimed an excess of $356,121 applicable to our audit period. In addition, Gateway received reimbursement checks related to the FCC's E-Rate; however, it did not credit its Head Start grant through cost reductions…

We recommend Gateway update and follow its procedures to ensure compliance with all Federal requirements and the accuracy of cost information, including cost proposals, submitted to ACF. Gateway did not comply with Federal requirements related to new construction and major renovations of its Head Start facilities. Gateway inappropriately used Disaster Relief Act funds, did not establish that it had a lack of suitable facilities, and submitted an unreliable cost comparison for the construction of a $22 million facility. In addition, Gateway requested and received funds for major renovations based on a cost estimate that was neither accurate nor prepared by…

We recommend that Gateway ensure that costs are allocated to Federal awards in accordance with the relative benefits received.

We recommend that the Administration for Children and Families ensure that Gateway complies with Federal requirements and verify information submitted by Gateway to support Gateway's grant award applications, including requesting Gateway to obtain independent analyses of cost comparisons for Head Start facility construction and major renovations.

Determine the allowability of the questioned transactions and recover $8,008,786, if applicable.

We recommend that BCBS of SC decrease its Excess Plan Partial Medicare Segment pension assets by $2,796,877 and recognize a negative $10,750 as the Excess Plan Partial Medicare Segment pension assets as of January 1, 2017.

We recommend that BCBS of SC develop and implement policies and procedures to ensure that going forward, it calculates Medicare segment pension assets in accordance with Federal requirements.

Rec. 2.a-b: The DoD OIG recommended that the Commander of the Naval Aviation Warfighting Development Center develop guidance for Navy personnel maintaining Naval Aviation Warfighting Development Center aircraft that includes a clear definition of the: a. Minimum number of mission-capable aircraft that aligns with Naval Aviation Warfighting Development Center's readiness standards to complete the required operational flights to meet carrier air wing training requirements. b. Aircraft system requirements in the Mission-Essential Subsystems Matrix for aircraft used as adversary aircraft for carrier air wing training.